Limited Liability Companies have become one of the most common forms of business organisation in the United States. Their main attraction is a combination of limited liability for LLC members…
…UAE-based company) entered into a Service Agreement with an Indian company for provision of services during the 2009-10 and 2010-2011 financial years for which it received a total consideration of…
…exchanged his shares in a French company for shares in a Luxembourg company. In 2002 he sold part of his shares in the Luxembourg company to a French company at…
…a tax audit. Unfortunately several other member states seem to have comparable systems. A strange development within a European Union where companies are often blamed for their tax planning but…
…of mismatches (see European Commission, Communication from the Commission to the European Parliament and the Council, A Fair and Efficient Corporate Tax System in the European Union: 5 Key Areas…
Google’s international corporate structure and operating model has featured significantly in the political and legal debate about the taxation of multinational companies, particularly in the technology sector. Although presented in…
…in the value creation, thus allowing a company to differentiate itself from the competition. Failure to consider such aspects will undermine a comprehensive understanding of the drivers for value creation….
…has come to broad public attention and under unprecedented public scrutiny in recent years, the Commission’s plan makes sense. Transparency towards tax authorities is an important instrument to tackle alleged…
The Committee on Economic and Monetary Affairs and the Committee on Civil Liberties, Justice and Home Affairs of the European Parliament recently finalized the amendments to the existing Anti-Money Laundering…
…the BEPS package and to which all countries (including India) that are a part of the Inclusive Framework on BEPS have committed to (with some degree of flexibility). India’s position…
…a Member State as compared to stand-alone companies. Hence, in the State aid investigations into tax rulings and transfer pricing, the European Commission does not refer to the at arm’s…
…the old treaty. The not yet in force Argentine treaties with Mexico and UAE contain a combination of PPT and SLOB, and a LoB, respectively. ↑13 http://www.keepeek.com/Digital-Asset-Management/oecd/taxation/making-dispute-resolution-mechanisms-more-effective-action-14-2015-final-report_9789264241633-en#.WVUB9-s18vk ↑14 https://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-BEPS.pdf https://www.oecd.org/tax/treaties/explanatory-statement-multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-BEPS.pdf…
…misalignments between taxable profits and commercial profits which could be a source of double non-taxation. In the view of the EU Commission, downward compensating adjustments should be undertaken only if…
…examples: one illustrating an appropriate adjustment where the exploitation phase commences much faster than the contracting parties priced them for (example 1A), but where the compensation adjustment is less than…
