The Fundamental Approach for Allocation of Risks and Returns for Financing Entities
…T (resident in country T) grants a loan to an affiliated company S (resident in country S). Company T has no employees and all decisions related to the loans are…
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From a FAR to a FARM Analysis with respect to Profit Attribution to the Indian Significant Economic Presence (SEP) Test
…as cloud computing solutions as provided by Microsoft Azure or SalesForce.com. Accordingly, the question arises as to how can market States tax (in particular highly) digitalized businesses as the current…
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The Contents of EC Tax Review, Volume 27, Issue 4, 2018
…The Road Ahead Is Still a Rocky One The e-commerce VAT package that was adopted in December 2017 is a key element of the European Commission VAT Action Plan and…
Spanish Courts Confirm Interest Withholding Tax Exemption is Not Subject to Beneficial Ownership Test
…been applied without any issues since it was enacted and has allowed Spanish companies to access international financing without the increased costs that gross-up clauses bring to borrowers in high…
The ideal corresponds to the idea and beauty to form; hence idea and substance are cognate – Victor Hugo
…f.k.a. Reserve Casualty Corp. v. Commissioner of Internal Revenue, T.C. Memo. 2018-86, 18 June 2018. In that case the court held that a captive insurance company incorporated in Anguilla and…
SCOTUS: The Crucial Case of South Dakota v. Wayfair and its Impacts for the Taxation of the Digital Economy
…on June 20, 2018. Available at: <https://kluwertaxblog.com/2018/06/20/old-bottles-new-bottles-time-break-bottle-favor-broader-source-country-taxing-rights/>. [3] See BRAUNER, Yariv. Taxing the Digital Economy Post-BEPS, Seriously. Intertax, Volume 46, Issue 6/7, pp. 462-465. Kluwer Law. Available at: <https://www.kluwerlawonline.com/abstract.php?area=Journals&id=TAXI2018050>. ______________________________________________________________________________…
Old Bottles or New Bottles: Time to Break the Bottle! In Favor of Broader Source Country Taxing Rights
…a comprehensive solution to the challenges of digitalization of the economy have tried so hard to create “something new”, without rejecting the starting points of the so-called international tax regime….
The Contents of Intertax, Volume 46, Issue 6/7, 2018 – Special Issue on Digital Taxation
…comprehensively. The OECD Interim Report 2018 and the EU proposals on digital taxation are already taken into account in some of these articles. After the critical editorial by Yariv Brauner…
Peace and Low Taxes
Economic development has been historically associated with the fulfilment of two major conditions: a) Peace and b) low taxation. Peace was the necessary component for prosperity from the point of…
The Contents of EC Tax Review, Volume 27, Issue 3, 2018
…promotion is often a key component within a company’s promotional campaign. Sales promotion consists of the use of a number of sales promotion techniques (SPTs). Although the use of SPTs…
Spanish case law on tax treaties: real estate companies… or not
…company). However, in this case, the question is a classic one: how to assess whether the company’s assets are mainly immovable property. While the Commentaries on the OECD Model only…