…be advisable for a comprehensive explanation to be provided, so that taxpayers are aware of their circumscribed options in relation to the application of Australia’s anti-abuse provision. The OECD has…
…arm’s length principle, mainly or almost exclusively based on comparable transactions among unrelated parties, in cases where comparable transactions do not exist, in order to achieve an arm’s length result….
Following three years of investigation, McDonald’s has been cleared from the charge that it received fiscal state aid from Luxembourg, by virtue of the European Commission’s concluding decision of 19…
…under art. 47, entitled “Supply of More Than One Component”, the detailed determination of “the tax treatment of any supply composed of more than one component for a single price,…
By now, warranty & indemnity (W&I) insurance is more or less a transaction solution commodity. As such, it clearly has entered its next product life-cycle phase. Expectations are that stand-alone…
…being that Indian companies will not be allowed deductions if they did not comply with the provisions of the Income Tax Act). Now, one can point to several provisions in…
…interest payments to a foreign related company – borrower may be recaptured. This has been upheld by the Supreme Court, deciding on an inbound loan from a German parent company…
…taxation, complies with the arm’s length standard as established by the competent Contracting State. In such context, the Brazilian commitment to provide access to MAP in line with the minimum…
…The taxpayers would then skilfully find deficiencies and gaps of the new laws, trying to still avoid heavier taxation, while complying at the same time with the law. Governments would…
…Conseil d’État, the Commission received several complaints from undertakings unable to request reimbursements of advance payments made by French companies which had received dividends of foreign origin. The Commission sent…
…digital business models are effectively taxed, while it is commonly agreed that the existing rules are not adequate. The reason invoked by the Commission for running ahead of the OECD…
…entity achieves. Captive insurances are by nature less diversified as compared to commercial insurers, therefore, a slightly higher capital ratio seems to be justified. Furthermore, the quality of assets is…
…is not identical to the PPT. It has important features in common. Was the transaction abusive? The Luxembourg company accepted that it derived a tax benefit from the restructuring of…
…<http://www. internationaltaxreview.com/Article/3832008/Mexico-confirms-that-US-may-qualify-as-a-preferential-tax-regime-in-light-of-the-2017-Tax-Cuts-and.html>. Last access on September 14, 2018. [2] See EUROPEAN COMMISSION. Fair Taxation: EU publishes list of non-cooperative tax jurisdictions. Brussels, published on December 05, 2017. Available at: <http://europa.eu/rapid/press-release_IP-17-5121_en.htm>….
