Taxing where value is created in a post-BEPS (digitalized) world?
…in any way affect the capital available to the company (leaving aside the marginal effect on the company’s valuation); it is therefore not any risk-bearing on the part of the…
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The Contents of Intertax, Volume 46, Issue 5, 2018
…& Frederik Zimmer) is a comparative research work on the retroactive application of tax information exchange agreements (TIEAs) in Brazil, Colombia, South Africa and Uruguay, with a view to articulating…
India’s position on PE rule bound to increase international tax litigation
…company would depend wholly on the existence or non-existence of a PE of that company in the source country. Work undertaken by the OECD in the area of corporate tax…
Active Business Test in the MLI’s LOB rule: The Second and Third Subtests
…through its officers and/or employees, e.g. a typical manufacturing company. The “active status” of this company is not enough to obtain treaty benefits. They may be obtained by the company…
Value Creation: Old wine in new bottles or new wine in old bottles?
…on the relationship between “value creation” and “source”. The clearest explanation of the meaning and identification of the source of income has come from the courts of Commonwealth countries who…
The Contents of Intertax, Volume 46, Issue 4, 2018
…principle, taxation of capital gains should be part of a comprehensive tax system that taxes a comprehensive concept of real net income and, if so, what are the key issues…
Active Business Test in the MLI’s LOB rule: The First Subtest
…the term “active conduct of a business” several activities and combinations thereof: (i) operating as a holding company; (ii) providing overall supervision or administration of a group of companies; (iii)…
Corporate Income Taxation, CSR and the UN’s 2030 Agenda for Sustainable Development
…the taxpayer. Like all complex sets of regulations, tax law is replete with linguistic imperfections. Tax laws can be conflicted, ambiguous, gap-riddled, overly-complex, vague, underenforced, and subject to regulatory capture….
The Contents of Intertax, Volume 46, Issue 3, 2018
…Have CFC Rules Become Redundant? Title question of the article is deliberately provocative. The subject of interactions between Controlled Foreign Company (CFC) regulations and transfer pricing (TP) regulations is a…
International Taxation, Epistemologies of the South, and Institutional Capacities: Transfer Pricing and the Universalization of the OECD Standards
…29 in a panel chaired by Luís Eduardo Schoueri and composed of Isabel Verlinden, Jefferson Vanderwolk, Mateus Calicchio Barbosa, Natalia Quiñones, Richard Vann, and Yariv Brauner. After a morning of…
The Contents of EC Tax Review, Volume 27, Issue 2, 2018
…is generally found to be complex and susceptible to VAT fraud. The legislative proposals for a definitive VAT system for cross-border trade as announced by the European Commission on 4…
Brexit: Transition brings tax-related controversy
…Regulation (EU) No 904/2010 on administrative cooperation and combating VAT fraud, Regulation (EU) No 389/2012 of 2 May 2012 on administrative cooperation on excise duties and Directive 2010/24/EU of 16…
Some remarks on the practical implications of the EU black list
The first common EU list of non cooperative tax jurisdictions – commonly referred as the EU black list – was released on 05 December 2017. It included seventeen offshore countries:…
Six questions plus one about the proposed EU Directive on the taxation of a “significant digital presence”
On 21 March, just a few days after the publication of the (frankly not exciting) OECD report on the tax challenges of digitalization, the European Commission presented its own “package”…