TP by numbers (2/3)
…company sheets described just before, do already cover the second and third bullets of that chapter. In addition, pulling this data by account instead of company (think e.g. “intercompany license…
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Tax & Innovation: 3 axes, a few links and some (personal) views
…being done and what can be done to make tax compliance easier and more user-friendly. Let’s start easy, pre-compiled tax returns should become the norm soon in many countries, saving…
Texas Hold’em Poker: France Bet Google & McDonalds. Will U.S. Treasury Double Down?
…may not, have a PE. Whether the activities of the Irish company in France, or the French company on behalf of the Irish company, rise to the level of a…
The CV/BV Structure in the Post-Starbucks Era: Inadmissible State Aid, Yes or No?
…in turn participating in a Dutch-based private limited-liability company (BV) that acts as a holding company on behalf, more often than not, of the various European operating companies. The CV…
International Taxation and the Moral Debate
…the international tax framework needed to be entrusted to a technically-competent multilateral body, which were also capable of summing up to the common endeavor as much participants as possible. In…
The Contents of Intertax, Volume 44, Issue 4, 2016
…budget. The European Commission (EC) has presented in the last decade numerous measures to combat VAT fraud. An analysis of these measures shows that Member States seem to address this…
Indian Court delivers important ruling on the interplay between international and domestic tax law
…T Rajkumar, K Dhanakumar, and T K Dhanashekar (collectively “petitioners”) – entered into a tripartite securities transfer agreement, under which a Cypriot company agreed and undertook to sell its shares…
The Brave New World of AML and Tax Compliance Overlap for Tax Status Certification for FATCA, CRS and the EU. Why are so many compliance officers getting it wrong?
This month I will discuss the important topic for the anti-money laundering compliance officer, wherein the AML systems overlap with the requirement for tax compliance, and that tax compliance requirement…
Current Issue of EC Tax Review
…establishing international organization for integration (EAEU) and the economic and legal space (the Customs Union and the Common economic space). The important aspect of the proposal is the comparative study…
The Panama Papers Affair and the challenges ahead: AEOI and Beneficial ownership
…owners). In the same line, the UK government has already made arrangement with overseas territories and Crown dependencies for the sharing of beneficial ownership information; see https://www.gov.uk/government7organisations/cabinet-office, and https://www.gov.uk/ government/organisations/foreign-commonwealt-office…
Pension funds and tax treaties: “Four legs good, two legs bad” or “Four legs good, two legs better”?
…fund to another. Amendments to the Commentary to Article 18 of the OECD Model Tax Convention addressed some of the complex issues relating to retirement savings and payments. This included…
TP by numbers (1/3)
…the methods and their application. An average P&L First (for the benefit of lawyers like me), let us list the main components of a typical P&L. Those components and their…
Panama Papers: Four (personal) reflections – beyond the media storm
The dust has not settled yet and there is probably much more to come from this and future leaks. Investigations have started, international cooperation will be key and hopefully those…
U.S. APA Transfer Pricing and LB&I ReStructure / Audit Process Update
…foreign partner Revenue authorities have not committed the resources necessary or do not have the expertise yet to reduce the median completion time for BAPAs. Unfortunately, given the advent of…