…Withholding will be required if royalties are paid by a non-UK resident company to another non-resident company in a no or low-tax jurisdiction. This is a common feature of the…
…and E-Commerce: Taxing Business Profits in the New Economy. [8] www.oecd.org/…/tax-challenges-digitalisation-part-2-comments-on-request-for-input-2017.pdf [9] https://www.youtube.com/watch?v=pDmxwlkJkDQ, https://www.youtube.com/watch?v=PcJMt75wDgM [10] See Teijeiro, MLI minimum standards on treaty shopping and mutual agreement procedure. LATAM countries’ position,…
…is computer speak for saying Excel can do 2 dimensions (rows and columns) only, not more. The more computer savvy tax professionals will then realise that Microsoft Access should be…
…each appoint members to a joint committee, known as the ‘conference committee’. This committee will negotiate between the two versions of the bill by section until identical language evolves for…
…taxpayer, the competent Court shall issue an order for implementation of such rules. They appeal a decision of a national tax authority rejecting a taxpayer’s complaint/application for initiation of dispute…
…the countries may use a combination of specific factors to determine whether a foreign company can be said to have a “purposeful and sustained interaction with the economy of the…
…the Advisory Commission with the consent of the competent authorities. An Advisory Commission or Alternative Dispute Resolution Commission may require the taxpayer to appear before it and also has power…
…and need to introduce them. Needless to say, this will affect many companies worldwide. Many tax experts are frowning upon these developments. They are especially critical about the so-called model…
…France, Spain, Italy, Germany, Austria, Bulgaria, Greece, Portugal, Romania, and Slovenia. [9] https://www.euractiv.com/section/economy-jobs/news/tax-fight-draws-divisions-at-eu-digital-summit/ Digital giants urged EU to refrain from unilateral moves on this area right thereafter https://in.reuters.com/article/us-eu-tax-digital-usa/u-s-companies-urge-eu-to-refrain-from-unilateral-moves-on-web-tax-idINKCN1C113B [10] http://www.oecd.org/tax/beps/oecd-invites-public-input-on-the-tax-challenges-of-digitalisation.htm…
…Program and Business Solutions, an Assistant Deputy Commissioner of Compliance Integration, and the Assistant Deputy Commissioner International. The practice areas study compliance issues within their area of expertise and suggest…
…This instrument may be issued by companies established under the corporate law of a number of civil law jurisdictions including both Austria and Germany. They are unknown in common law…
…compensation; one does not deduct a residual compensation from a routine compensationI assume that this method of calculating the PE profits were chosen, because the authors realised the practical impossibility…
…the European Union {COM(2016) 686 final} {SWD(2016) 344 final}. ↑3 COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE Double Taxation in…
…the basis of the complexity of the MLI, which intends to amend several bilateral tax treaties through a single instrument. According to the Brazilian Tax Administration, this innovative procedure could…
