…be responsive to communications from the U.S. regarding an IGA or if the jurisdictions has communicated its potential inability to sign or implement an IGA. Has not seemed to push…
…of each CTA. Agreement by computer matching In order to work out who has agreed what with whom, the OECD has commissioned software that will determine compatibility between the positions…
…more complex – too complex. With as result that many authorities now have become less inclined to adhere to them. Instead, their preference is for standards of their own invention…
…location of reported profits, it reduces the incentives for profit-shifting and international tax avoidance schemes. Furthermore, the DBCTF may also reduce compliance costs and the harmful competition in the international…
…tax treaties the “tie breaker” rule for dual resident companies, which requires a mutual agreement between competent authorities in order to resolve dual residence (rather than to give preference to…
…correctness dictates that certain taxpayers do not pay their “fair (?) share” of taxes, although they do comply to tax laws in force; in this era, in order to increase…
…venue. Jaypee was to receive a consideration of USD40m under the RPC. All the commercial rights in relation to the racing event were vested with Formula One. Will income attributable…
…establishment in India under article 5(1) of the India-UK double tax treaty (Formula One World Championship Ltd v Commissioner of Income Tax, International Taxation). FOWC granted Jaypee, an Indian company,…
…Code recently released by the European Commission. Amongst others, the Commission put forward the importance of taxpayers’ education at an early age regarding the function of the tax system, its…
…in India. A ruling handed down by the New Delhi Income Tax Appellate Tribunal (Geo Connect Ltd vs. Deputy Commissioner of Income Tax; 2017) fortifies some of the most common…
…(FATCA) of the IRC. The FATCA regs are highly complex but the complexity comes from the IRS responding to industry. The tax code could be much simpler. The complexity results…
…doctrine may apply. Compared to the Schumacker case, the decision in the X case takes a few steps forward. The CJEU in the X case required the source state to…
…referring to Treas. Reg. §1.482-7(d)(2) (2003). [16] Amazon.Com v. Comm’r, T.C. Memo 2014-149, Docket No. 31197-12 (July 28, 2014). Available at http://www.ustaxcourt.gov/InOpHistoric/amazon.com,inc.memo.lauber.TCM.WPD.pdf (accessed March 23, 2017). (Hereafter Amazon.com Inc. (2014))….
…enterprise theory). It also leads to absurd results which will never happen in reality. E.g. if a drilling company drills in a foreign company for 8 months, that could create…
