Could I Please Get a Fiat for the Price of my Frappuccino?
…many complexities in tax systems. In both cases the European Commission found that the tax authorities had agreed to a tax treatment that was more favorable than what should have…
…many complexities in tax systems. In both cases the European Commission found that the tax authorities had agreed to a tax treatment that was more favorable than what should have…
…Committee discuss the work done by its various sub-committees during the past year and to decide the next year’s tasks for those committees. The frequency of meetings is to be…
…present discussions are based on alternatives that cannot be explained under the ALS. More dramatically, the intent to combat BEPS has led to suggestions that, if adopted, will completely jeopardize…
…possibility of transferring the losses incurred by a non-resident company to a resident company entails the risk that within a group of companies losses will be transferred to companies established…
…implemented cautiously and discretionally. Fairness wise, protection of taxpayers’ rights and tax dispute resolution measures should be administered and adjudicated compatibly under international tax routines. For the sake of efficiency,…
…complete instrument by end 2016. Maybe not all countries negotiating may sign, but for those who do, there will be a mass amendment of their treaty networks regarding actions 2…
…now under the motto: “tax avoidance can be combated by means of a common tax base” (COM(2015) 302 final). Also something that we women are good at: raking up the…
…also coming before national courts. Multilateral treaty Unlike the firm commitment to include provisions in the proposed multilateral treaty that have been developed to address tax administration concerns relating to…
…limited liability companies than the common corporations. In my view, the lack of a correspondent may lead to difficulties in assessing the transparent character of a foreign business entity for…
…through its FATCA portal. The IRS provides these FFIs a Global Intermediary Identification Number (GIIN). The FFI may then use its unique 19 digit GIIN to complete the IRS tax…
…this is, the act of filtering ill-gotten gains or dirty money back into de formal economic circle.(3) The following common features may be found by comparing the definitions of tax…
…and registered deemed-compliant FFIs (other than FFIs covered by an IGA) in the group. Branches that continue to operate after December 31, 2016, in jurisdictions where they cannot comply with…
…fair competition within the market of the source State. One can imagine a situation where several MNEs compete in a very same local market, all of them importing the elements…
…the Convention on the Protection of the European Communities’ Financial Interests,[2. Council Act of 26 July 1995 Drawing Up the Convention on the Protection of the European Communities’ Financial Interests…