…planning/tax mitigation are clashing with the CSR levels actually desired. CSR is described as an area that compels companies to take into consideration the interests of the stakeholders’ community, on…
…good sold or service provided to a related company. In particular, the CUP method consists in observing a comparable transaction between two independent companies and applying the same price for…
…Combatting tax avoidance – that is: combatting the citizens’ freedom not to pay taxes if a law allows them not to – is the new political correctness. Last but not…
…of these payments if compared to other treaties, leaving them with a more favourable treatment from the source-state point of view. According to this position, countries like Spain and Switzerland…
…investigations of company-specific tax rulings, and nearly all of the amounts at stake, involve U.S. companies” and that the European Commission is “disproportionately targeting U.S. companies.” But in addition to…
…US Congress on this dossier. After all, US companies doing business in Europe, along with EU companies will be forced to publish their cbcr once the EU adopts this publication…
…of offshore close companies have been reformed with the fundamental freedoms in mind. The main effect of these changes has been to keep the UK tax system open and competitive…
…companies negatively. We have seen many companies suffering severe reputational damages, having lost public and private costumers, with significant drops in share prices – all due to negative media attention,…
…PE or are not backed by commensurate substance. While aggressive tax planning by multinational companies may have been the cornerstone for the recent upswing in activity to prescribe rules for…
…purposes. To support its conclusion, the Commission also points to the OECD Commentary on Art. 23A, which addresses possible cases of double non-taxation. Before looking further into the Commission’s own…
…Cayman Islands Central African Republic Chad Chile China Christmas Island Cocos (Keeling) Islands Colombia Comoros Congo Cook Islands Costa Rica Cote D’Ivoire Croatia Cuba Curacao Cyprus Czech Republic Democratic Republic…
…published in 2010; the 2015 update was aimed at providing guidance to governments wishing to offer taxpayers the chance to come forward and become compliant, regularizing their tax affairs by…
…Part IV. Certified deemed-compliant nonregistering local bank. Complete Part V. Certified deemed-compliant FFI with only low-value accounts. Complete Part VI. Certified deemed-compliant sponsored, closely held investment vehicle. Complete Part VII….
…in tax treaties concluded by industrialized countries and countries with emerging economies. It then proposes a more ambitious novel approach which would seek a comprehensive solution binding on all parties…
