Nike State Aid Comments
…preliminary decision with the reasoning that The Netherlands government provided Nike an anti-competitive subsidy via the tax system. My paraphrasing of the following EU Commission statement [para. 87] sums up…
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BEPS, Double Taxation, Hybrids, International Tax Law, MLI, OECD, Residence, Tax Treaties, Treaty shopping, United States
Investment funds- Tax classification and entitlement to treaty benefits
Commissioner of Taxation v Resource Capital Fund IV LP [2019] FCAFC 51 addressed a number of fundamental international tax issues. The case concerned a gain from the sale of shares…
Are We Finally Coming into Terms on the Taxation of the Digitalized Economy? A View from a LATAM Perspective
…economy of that country via technology and other automated tools. In turn, a presence of that sustained interaction comes from a combination of (i) a revenue-based factor, i.e. transactions with…
The OECD/Inclusive Framework’s Program of Work on Revised Nexus and Profit Allocation Rules (Pillar One): Where Will It Lead?
…2019. Rather, the introductory chapter of the program document notes, first, that “for some commentators and members of the Inclusive Framework the work on the tax challenges of digitalization has…
Is Finland the Next Crypto Tax Super Power?
…Companies Act that would be needed to reach comparability with equity investment. The related ICO income should be exempt from income tax and VAT as injection of equity or debt…
Transfer Pricing Documentation: It Is All about the Looks
…basis for all other related distributor files across the globe. Worse is that it can give a false sense of security, technical accuracy and completeness. Different formats across companies hinders…
Altera: An ‘arm’s length result is not simply any result that maximizes one’s tax obligations’
…6, 2010) (detailed explanation of the IRS’ reasoning available at http://www.irs.gov/pub/irs-aod/aod201005.pdf, assessed June 7, 2019). [17] Altera I. [18] Amazon.Com, Inc. v Commr, 148 TC No 8 (March 23, 2017)….
Mutual agreement procedure: Taxpayer access to information
…OECD Commentary The FTT observed that article 25 does not itself deal with disclosure to the taxpayer and that paragraph 61 of the OECD Commentary on article 25 says that…
Swiss Tax Reform and its Impact on the Canton of Geneva
…24.17% in 2019 (for companies without preferential tax regimes). For the sake of comparison, all tax rates below are a combination of federal, capital city and respective canton rates (here…
The Contents of Intertax, Volume 47, Issue 6/7, 2019
…tax that is commensurate with the relevant economy and the prevailing tax rules compared with tax actually collected) and tax as a means of redistribution of income and wealth in…
Withholding Taxes in the Digital Economy Era
…the UN Model Tax Convention attributing taxing rights to the source state in relation to fees for technical services. By covering all services, the proposal avoids the complexity often linked…
Rethinking Article 15 of the OECD Model in Light of Digitalization
…the models in use today. In addition to the mundane conclusion (already made by earlier commentators) that if a common understanding of the term “employment” truly exists, an autonomous definition…
Can PPT-LOB Clause Plug the Loopholes Inherent in PCC Entities?
…suited to indulge in treaty shopping in spite of PPT and LOB conditions. One such is the Protected Cell Company. The Protected Cell Company Protected Cell Companies (PCCs) are pre-structured…
The International Taxation of Autonomous Artificial Intelligence (AAI): Questions from Prof. Xavier Oberson
…Volume 09. 2018. Available at: <https://www.mdpi.com/2078-2489/9/9/230/pdf>. [13] A deeper, perhaps more troublesome issue with treating AAI as an individual, involves giving AAI the same individual rights that taxpayers have in…