CbCR: Compliance should not be this difficult (and the solution)
…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…
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Excise Tax on Related Party Transactions: Give With One Hand But Take With The Other. Do the International Tax Reform Provisions Align With Tax Treaties?
…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…
Tax Dispute Resolution Directive: An Important Step for the EU
…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…
Should we supplement physical PE with a virtual PE to tax digital services?
…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…
Arbitration, BEPS, Double Taxation, EU/EEA, MAPs and APAs, MLI, OECD, Tax Treaties, Transfer Pricing
EU sets the standard for international tax dispute resolution
…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…
The world needs CFC rules that tax profits where value is not created
…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…
A call for a Sustainable Response to the taxation of Digital Economy within the International Income Tax System
…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…
2017 U.S. Transfer Pricing and Intra Group Pricing Update
…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…
The European Court of Justice and Interpretation of Tax Treaties
…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…
Still busting ghosts: imaginary people do not function very well: Thoughts on the second OECD draft guidance on BEPS Action 7
…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 Court of Justice as Court of Arbitration for Disputes under DTA’s (Case C-648/15, Austria v Federal Republic of Germany)
…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…
Brazil’s absence from the Multilateral BEPS Convention and the new amending protocol signed between Brazil and Argentina
…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…
US LLC’s – transparent or not: another struggle continues
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…
Addressing tax challenges of the digital economy: fair play or foul play?
…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…