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Double Taxation, MAPs and APAs, OECD, Tax Treaties, Transfer Pricing

Transfer Pricing Policy: Should the Relief Mechanism Dealing with Corresponding Adjustments Be Reconsidered under Tax Treaties?

Pitambar Das (Tax Policy Division, Ministry of Finance, India) and Vikram Chand (Editor) (Tax Policy Center of the University of Lausanne, Switzerland)/May 27, 2019 /Leave a comment

…the authors welcome comments from the international tax community on this blog. The authors would like to thank Mr Johann Muller, Mr Stefaan De Baets, Mr Balthasar Denger and Dr…

BEPS, Digitalization, India, Tax Avoidance

“Loophole Games”: understanding corporate tax avoidance in India

Shilpa Goel (Tax Lawyer)/May 24, 2019May 25, 2019 /2 Comments

…of these strategies are not unknown to businesses and their tax advisers. The idea of the book is to communicate these to the common man (and the media) in a…

Digitalization, Equalization levy, India, Tax Treaties

Ruminating over Equalisation Levies

Dhruv Janssen-Sanghavi/May 23, 2019May 23, 2019 /Leave a comment

…Ottawa Conference first recognized that “e-commerce” was ushering fundamental changes to the global economy. It is not surprising that countries would wish to find ways and means to address their…

Abuse of law, EU/EEA, Mandatory disclosure, Tax Avoidance, Tax Fraud

The New Directive on Whistleblowers’ Protection: Any Impact on Taxation?

Katerina Pantazatou (University of Luxembourg)/May 22, 2019May 21, 2019 /1 Comment

…that affect the competitiveness of the companies in the internal market, directly linked to the free movement rules and also relevant for the application of the State aid rules.” (emphasis…

Intertax

The Contents of Intertax, Volume 47, Issue 5, 2019

Ana Paula Dourado (General Editor of Intertax)/May 20, 2019May 20, 2019 /Leave a comment

…Competence to Tax: A Comparative Legal Study of Municipal Taxes in Belgium and the Netherlands This article describes and compares the possibilities under Belgian and Dutch law for taxation by…

Digital services tax, EU/EEA, India, OECD, Tax Policy

User Value and Taxation of the Digital Economy

Jim Stewart (Trinity College Dublin)/May 9, 2019 /3 Comments

…The EU Competition Commissioner and possible candidate for European Commission presidency, Margrethe Vestager, has called on European countries to take the lead, if global initiatives led by the OECD do…

International Tax Law, Value Creation

Source of income: “proximate origin” – “originating cause” of profit earned

Jonathan Schwarz (Temple Tax Chambers; King’s College London)/May 7, 2019August 26, 2021 /Leave a comment

…an investment committee of the general partner outside Australia; before making important decisions, an investment committee of the general partner took advice from the management company, RCF Management, outside of…

BEPS, India, OECD, Principal purpose test

Does the Principal Purpose Test (PPT) Throw Tax Certainty to the Winds?

Ashish Goel (Advocate)/May 2, 2019May 2, 2019 /Leave a comment

…nothing can be said to be certain, except death and taxes.” Franklin was right then and he is right now. However, there is one more commonality between death and taxes,…

Intertax

The Contents of Intertax, Volume 47, Issue 4, 2019

Ana Paula Dourado (General Editor of Intertax)/April 26, 2019April 16, 2019 /Leave a comment

…Unanimity for a Qualified Majority in the Tax Field”, focuses on the European Commission Communication to the European Parliament, the European Council and the Council, “Towards a more Efficient and…

Anti-tax avoidance, BEPS, International Tax Law, United States

The Great Recession and the International Tax Regime

Reuven S. Avi-Yonah (University of Michigan)/April 23, 2019April 18, 2019 /2 Comments

…terms of combating tax avoidance, because it took the position that it was already compliant with BEPS, rejected the PPT, and did not sign the MAATM. But the 2017 tax…

EC Tax Review

The Contents of EC Tax Review, Volume 28, Issue 2, 2019

Ben Kiekebeld (General Editor EC Tax Review and tax adviser at Ernst & Young Belastingadviseurs LLP)/April 19, 2019March 28, 2019 /Leave a comment

…tax (‘CIT’) instead. While non-resident companies are subject to immediate taxation, resident companies could benefit from a cash-flow advantage when they remain in deficit, or even a permanent exemption when…

Demerger, Switzerland, Tax neutrality

Swiss Federal Supreme Court Renders Decision on Tax Neutrality of a Holding Company Demerger

Peter Reinarz (Reinarz Tax & Legal)/April 18, 2019 /1 Comment

…it was principally possible for a Swiss holding company to undertake a tax-neutral demerger, such that the existing holding company could transfer just one qualifying participation in an underlying active…

Double Taxation, International Tax Law, OECD, Tax Policy, Tax Treaties, United Nations

When is a tax treaty not a treaty?

Jonathan Schwarz (Temple Tax Chambers; King’s College London)/April 12, 2019 /2 Comments

…consent at the international plane. Kenya, like many Commonwealth countries has legislation of a general nature to give effect to treaties under domestic law. In Kenya this is governed by…

EU/EEA, Tax Policy, Tax Treaties, Transfer Pricing

A New Addition to the Editorial Team

Simon Bellamy (Wolters Kluwer, Legal & Regulatory, International Group)/April 12, 2019April 11, 2019 /Leave a comment

…Pricing, Tax Treaty and EU Tax Law matters. If you would like to get in touch with him and make a potential contribution, kindly send him an email on: klitaxblog@gmail.com…

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10058516-0002_OR2_290Schwarz on Tax Treaties, Sixth EditionJonathan Schwarz€ 211

Contributors

  • Svetislav V. Kostić (Managing Editor)
    University of Belgrade, Faculty of Law
  • Vikram Chand (Editor)
    Tax Policy Center of the University of Lausanne, Switzerland
  • Alice Pirlot (Editor)
    Geneva Graduate Institute
  • Dennis Weber (Editor)
    Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff
  • Błażej Kuźniacki
    PwC Netherlands, Lazarski University and Singapore Management University
  • Johann Müller
    International tax professional
  • Jakob Bundgaard
    CORIT advisory
  • William Byrnes
    Texas A&M University Law
  • Werner Haslehner
    Luxembourg University
  • Tianlong Hu
    Law School and International Monetary Institute, Renmin University of China
  • Christian Kaeser
    Siemens AG
  • Theo Keijzer
    Dorean Global Tax Policy BV
  • Guglielmo Maisto
    Maisto e Associati
  • Georgios Matsos
    Matsos & Associates
  • Luis Schoueri
    University of Sao Paulo; Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados
  • Jonathan Schwarz
    Temple Tax Chambers; King’s College London
  • Guillermo O. Teijeiro
    Bomchil
  • Ana Claudia Akie Utumi
    Utumi Advogados
  • Piergiorgio Valente
    Crowe Valente/Valente Associati GEB Partners; Link Campus University, Rome

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