Double (Non)Taxation, Transfer Pricing and State Aid
…The following example illustrates why: Example: Company A and Company B are associated enterprises residing in MS A and non-MS B, respectively. Each company reports profits of 100. Following the…
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The Netherlands Appeals the Starbucks Decision
…Review of existing internal comparables, if any. Step 5: Determination of available sources of information on external comparables where such external comparables are needed taking into account their relative reliability….
BEPS Project at half way – Entering the implementation stage
…proposals affecting DTCs, whose process is still active and programed to be terminated under a tight schedule.(8) Soon after the October 5 final release, all type of comments coming from…
Fifty shades of fair exit taxation of corporations
…given by the Commission in October 1990, declared outspokenly that the excessive competition between Member States must be hindered by setting a minimum level of statutory tax rates and common…
FATCA November GIIN and IDES Updates
…FFI GIIN registration and FATCA compliance will sharply jump. Some analysts forecast a divestment from the U.S. by these countries. But even if that case scenario comes to pass, the…
Darwin & Corporate Taxation – Has the Evolution of the Economy Killed the Basis for Corporate Taxation?
…by the OECD in the ambitious BEPS project and by the European Commission (“Commission”). The basis for the discussion is the Commission’s release from June 17 2015 titled “A Fair…
Are legal rights irrelevant for transfer pricing after BEPS Actions 8, 9 and 10?
…deliver the allocation of profits among the companies comprising those enterprises in the way that is now regarded as unacceptable profit shifting (OECD (2013), Addressing Base Erosion and Profit Shifting)….
How much would Starbucks pay me for coffee?
Introduction It has been a few weeks now since the Commission has made public its decisions in the FIAT and Starbucks cases. I understand that the Commission, the countries involved…
Non-discrimination under the Andean Community Law
…Favoured Nation” clauses.] (and despite the discredit of said community, particularly in recent years),[5. Venezuela left the Andean Community some time ago and Colombia is also considering the possibility of…
Why a 1999 EU study was kept a secret till now: France made tax deals outside the law.
…rumoured French connection” (http://www.kluwertaxlawblog.com/blog/2015/04/22/a-mysterious-study-in-the-code-of-conduct-report-1999-and-a-rumoured-french-connection/ ). The blog did attract attention and document discovery procedures started. Progress was made. On 20 October, 2015, the Netherlands Ministry of Finance sent the Study…
The Interplay between the State Aid Rules and other BEPS-Preventing Tools (SA.38375)
…2.[Case C 75/97, Belgium v Commission, EU:C:1999:311 [33] and [41]. See also Case C-56/93, Belgium v Commission, EU:C:1996:64 [73].]↩ 3.[C-452/10 P, BNP Paribas, EU:C:2012:366 [121].]↩ 4.[Case C-241/94, France v Commission,…
The “other” tax club more ought to follow, part 2
…regard to services in the offshore sector. The discussion covered the scope of the convention with regard to the geographic area covered and article 7. Imagine oil company R in…
The BEPS Project Lacks Comprehensive Definition on the Taxation of Digital Economy in Market Jurisdictions
…company. Bearing in mind that the basic directives on e-commerce in the Commentaries to Article 5, paragraph 7, subparagraphs 42.1 to 42.10 have remained unchanged since 2003 and are thus…
EU Commission State Aid Starbucks Decision – My U.S. Perspective
…shift profits to reduce the taxes paid by the company. It would give that company an unfair competitive advantage over other companies (typically SMEs) that are taxed on their actual…