Tax Planning – Beyond Substance and Business Purposes Analysis
…driven the acquisition of the target company. Another example was a case of a subsidiary of a US company, in which the authorities understood that the parent company did not…
…driven the acquisition of the target company. Another example was a case of a subsidiary of a US company, in which the authorities understood that the parent company did not…
…pending and perhaps that decision will completely change this view (5). This Brazilian position, however, is not completely isolated (6) and opens an important discussion, particularly in countries in which…
…23 to the commentary on article 1 of the OECD MC, “The use of base companies may also be addressed through controlled foreign companies provisions. A significant number of member…
…most comprehensive study I was able to find analyzes firm-level ETRs of companies in 82 countries from 1988 – 2009. The study finds that generally little difference exists between the…
Following my latest post on the Court of Justice’s decision in Commission v UK (C-172/13, ECLI:EU:C:2015:50), I want to turn in this comment on the related issue of currency losses,…
…OECD Common Reporting Standard signatories remains at 98, the major ironic holdout being the U.S., with 58 committed to begin in 2017, 35 in 2018, and 5 not yet committed…
…an investment vehicle, simply because they will not comply with the condition that more than 50% of the capital belongs to residents in the same treaty-partner country (it is common…
…an anti-abuse measure to deal with the creation of shell companies outside India but managed from India. The international tax community would be well served by a proposal that states…
…encourage the Commission to go further and to issue, before the June Ecofin Council, a comprehensive proposal to deal with double non taxation and harmful tax competition. Very positively they…
…Contracting State to tax its own residents under controlled foreign companies provisions found in its domestic law even though such tax imposed on these residents may be computed by reference…
…the following four-layer program. This post discusses the first layer of problem regarding the recently heavily debated topics on China’s efforts to internationalize its currency. Commitment to Innovative Reform in…
…at 98, with 58 committed to begin in 2017, 35 in 2018, and 5 not yet committed to the start date. Since the publication of the U.S. Treasury’s original GIIN…
…What is the issue? Paragraph 26, page 10, of the Code of Conduct Report ( 23.11.1999, SN 4901/99), reads as follows: “26. The Commission appointed consultants to undertake a comparative…
…overdue move would be a big step towards equitable tax treatment of individuals, notably in the Common Market in Europe. If individuals had been included in the scope of the…