EU BEPS / Taxing Low-Taxed Non-EU Income: Think Twice…
(about the switch-over clause in the ATA Directive) In order to combat BEPS, the European Commission is proposing to start taxing low taxed non-EU income. That sounds reasonable, but the…
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The Commission Proposal for an Anti-BEPS Directive: Some Preliminary Comments
…The Commission maintains in its Communication COM(2016) 23 that “issues relating more to tax treaties have not been included in the Directive”, but are instead tackled by a separate recommendation…
Shall International Tax Planning Drop Dramatically by Virtue of BEPS? It Depends
…GAAR rules already Countries which have a comprehensive and well established GAAR or anti-abuse doctrine may have little to change to achieve BEPS compliant standards. In such countries international tax…
Analysis of IRS Notice 2016-8: FATCA Extensions and Reliance Upon Electronic W8 / W9s
…certifications required of certain foreign financial institutions (FFIs); (2) specify the period and date for submitting to the IRS the periodic certification of compliance for a registered deemed compliant FFI;…
Imperial Taxation: The Awkward Protection for States Against Taxpayers in Contemporary International Taxation
…disclosure and combating opaque situations that prevent the due application of laws in general. Nevertheless, one should not forget: State and Government transparency come first. This maxim seems to have…
India Should Rework its Guidance on Place of Effective Management
…the executive committee, the company’s POEM shall be place where the committee is so based. However, the guidance fails to clearly illustrate the nature of decisions that shall be taken…
Will the US Impose Double US Tax Rates on EU Companies from Countries that Retroactively Impose State Aid Claw Backs?
…the EU Commission trying to soak up past earnings of US companies). My blog colleagues will likely retort that US double tax agreement obligations will protect such EU companies and…
Hidden or Accidental Permanent Establishments and Penalties
…its good faith in failing to declare and pay tax in South Africa. The South African Tax Court held that compliance in the US had no bearing on non-compliance in…
The Contents of Intertax, Volume 44, Issue 1, 2016
…governments hold towards the application of tax incentives in cross-border situations and the underlying rationales. Through the analysis of the relevant tax sources, tax jurisdictions are classified into four common…
“The United States of America is the most powerful nation on Earth.” What does this mean for the future of CV/BV-structures?
…an increased alertness.[6. See http://www.finance.senate.gov/chairmans-news/finance-committee-members-push-for-fairness-in-eu-state-aid-investigations-.] That’s why I can’t rule out the possibility that power play of the “most powerful nation on Earth” can lead to a widespread hybrid mismatch…
2015’s FATCA GIIN Analysis
…at the end of this post comparing 2014 and 2015 by IGA type, as well as a monthly breakdown of GIIN registrations since list publication began in June 2014. The…
Africa – to outsource tax compliance
…correct way to tackle tax compliance? Keeping it in-house compared to outsourcing it to a specialist service provider. Africa typically is a jurisdiction where specialist knowledge comes at a cost,…
Tax Risk Management in BEPS Times: A Trap for the Unwary?
…documentation aligning economic substance with the legal forms chosen to execute business transactions; and (iii) compliance procedures ensuring accurate and complete tax returns (including information returns for transfer pricing purposes)….
Agency Permanent Establishments: Commissionaires in the frame
The Spanish National Court has recently ruled (case no. 182/2012) that a Spanish affiliate of Dell that sold Dell computers in Spain under a commissionaire agreement with Dell Ireland constituted…