…the Belgian entity’s adjusted arm’s length profit was established by determining the profit that a comparable standalone company would have made in comparable circumstances. The difference between the profit arrived…
…certain issues related to its compatibility with domestic law and with tax treaty obligations. This article addresses one of these issues by analysing the compliance of the BEPS Action 4…
The Debate What makes a tax system competitive? How can countries multiply the competitiveness of the existing system? These question-marks are attracting substantial research by today’s policy makers, at national…
…the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States, as amended by Council Directive 2003/123/EC of 22 December 2003). This decision…
…be used when there are internal (i.e. where the borrower has other comparable independently guaranteed loans) or external comparables. Third party publicly available information on potentially comparable uncontrolled transactions (e.g….
…it did not consider the taxation of companies controlled by entertainers. Therefore, it decided to follow a more than doubtful dynamic interpretation of tax treaties to include in the 1972…
…calendaring, and task management) (https://www.clio.com); “Anaqua”, which protects g and manages IP portfolios (http://www.anaqua.com) and “Disco”, which focuses on e-discovery (e.g. storing and managing digital data in order to identify…
…students. McCarty also emphasised the technical complexity of tax law (tax law may be seen as the most technical areas of law), which is very difficult to comprehend and deal…
…minimum tax on the profits of multinational companies. Complex, easy to manipulate and unfair – there is widespread discontent with the current system of international corporate taxation. The increasing digitalization…
…complexity of a net income tax. Thereby they implicitly preferred endless compliance, endless mounts of TP documentation, application of complex Authorised OECD Approaches to profit allocations, benchmark studies, tax disputes,…
…a foreign entity. As such, the objective scope of the regime appears quite narrow, since, for instance, it cannot be opted by individuals who have worked for an Italian company…
…and trust to ensure the competitiveness of the Digital Single Market. To the same end, the EU adopted in June 2017 a common toolbox against cyber attacks in order to…
…a sad reality for many companies doing business in India. The consequence is that a cloud of uncertainty constantly hangs over cross-border, intra-group transactions routinely undertaken by these companies. An…
…tool for competitiveness; how can Europe become competitive in the post-BEPS era, and in the absence of corporate income tax harmonization; how can competitiveness help building communication and trust among…
