Exchange of Information: A Train Smash waiting to happen?
…no indication of the extent to which compliant taxpayers were compelled to demonstrate their compliance or the cost they may have incurred in doing so. There are few other areas…
…no indication of the extent to which compliant taxpayers were compelled to demonstrate their compliance or the cost they may have incurred in doing so. There are few other areas…
…a settlement practice which fall outside the scope of the current focus of the EU Commission. The question whether a favorable settlement may be considered a State aid comes from…
…of clarity: 2003-08 – Goodyear Philippines (“GP”) issues shares to Goodyear Tire and Rubber Company (“GT”) 2008-08 – Decision to redeem preference shares 2008-10-15 – Request to confirm redemption is…
…comparable is better than no comparable at all. We also accept that if we apply the RPM or TNMM making the comparison to independent distributors of similar goods the comparison…
…designer for several tier 1 financial institutions) and I (primary author, Lexis Guide to FATCA Compliance) have been analyzing on a monthly basis the list that the USA provides of…
…least drive the People’s Congress to consolidate and supervise government cash resources comprehensively and encompass all government cash resources, budgetary and extra-budgetary. To this end, the TSA system in China…
…of these countries forming a combined front of uniform rules and guidelines. Should Tax Uncertainty be a Problem for Future Business? Every uncertainty should be an opportunity. Most African countries…
…taxation of Brazilian investments in controlled or related companies located abroad. Based on the law, the taxation of the corresponding foreign profits will continue to be immediate for controlled companies,…
…longer investing in a country and moving to another country. That is part of the simple equation. Tax avoidance and genuine tax planning is a common practice by companies and…
…7 (7) before AOA was embraced in 2010) is clear enough in that profit is composed of several “items of income”, dealt with or not in a particular distributive rule…
…are by companies based in other EU member states such as Ireland and Luxembourg who have no UK PE, and where profits of those companies are reduced by payments to…
…proposal for a common consolidated corporate tax base, which has more or less been kept in the drawer since it was released in 2011. From within the EU, Competition Commissioner…
…general anti-abuse provision and common rules for Patent Box provisions. This letter does not come as a surprise after the Commission’s announcement to check tax rulings of several EU member…
…are coming from. We also hope that in time we will build a sense community where people strongly disagree on some points, but still respect each other, because they have…