…In the course of our panel discussion on dispute resolution post BEPS, I asked the audience of over 100 tax directors and managers of multinational companies how long their mutual…
…the latter applies to distributions of profits by subsidiary companies of a Member State to parent companies of other Member States. In turn, article 2 of that Directive defines “company…
…https://www.selectusa.gov/energy-industry-united-states (accessed March 109, 2017). [10] America’s Unconventional Energy Opportunity, Michael Porter, David Gee and Gregory Pope, Harvard Business School and Boston Consulting Group (2015). Available at http://www.hbs.edu/competitiveness/Documents/america-unconventional-energy-opportunity.pdf (accessed March…
…planning a disciplinary offence and, because of compliance with it, HMRC have intimated that such regulated professionals are not the target of the enablers legislation, which will come into force…
…of the nature of the parent company. What is worth noting is that the fact that a holding or a sub-holding company do not have a relevant organizational structure cannot…
…(potential breach of the Nations’ compact behind a common goal due to competing interests, and misaligned, premature and unilateral actions by States) which might conspire against the coherence and effectiveness…
…will be a great variety in the contents of bilateral treaties. The OECD committed itself to a multilateral treaty as the preferred mechanism to amend many bilateral treaties at the…
…by an Indian company or a permanent establishment of a foreign company to its associated enterprises in excess of thirty percent of EBITDA shall not be allowed as deduction in…
…tax on interest (in combination with interest deduction limitations), then parents will generally prefer financing local subsidiaries with equity, rather than debt. It is true however, that in a 25%…
…a mere 4,2% of the total revenue. Many multinational companies implemented and still implement complex tax structures, from hybrid financing to tolling structures. Many tax authorities deploy many resources trying…
…law is concerned only with the computation of ALP with respect to the profits realised by the taxpayer. Taking the foreign AE as the enterprise would amount to computing ALP…
…them, is a commendable step in the right direction and should be welcomed indeed. Hopefully, the year 2019 will see this dynamic and optimistic vision turn into reality. [1] http://www.mef.gov.it/ministero/oiv/documenti/Atto_indirizzo_conseguimento_obiettivi_politica_fiscale_2017_2019.pdf…
…will also limit the ability of the developing countries to apply their domestic laws for taxing non-residents and foreign companies.” India’s stance on MAP arbitration was unambiguous after the OECD…
…step to be taken is to look for and analyse potential internal comparables, if any (Starbucks, § 272). a. Selection of Comparables In the EU Commission’s view, the comparability analysis…
