Is it not Time to Correct the OECD MC Commentary on CFC’s?
…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…
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Effective Tax Rates in Multinationals and Domestic Firms
…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…
Is there such a thing as definitive losses? And if so, when? – Part 2
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,…
FATCA GIINs for May 2015
…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…
Interaction between BEPS Plan and LATAM Recent Tax Developments
…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…
A Future for the “Place of Effective Management”?
…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…
17th Meeting of the Franco-German Council of Ministers on 31 March 2015 Joint Communiqué by W. Schäuble and M. Sapin
…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…
The Objective Scope of Article 7 and the Treaty Protection to Deemed Distributed Dividends
…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…
Free Trade, RMB Internationalization, and Tax Reform Commitments
…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…
FATCA GIIN Registrations Update for April
…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…
A Mysterious Study in the Code of Conduct Report 1999 and a Rumoured French Connection
…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…
It is Time for Britain to change its Domicile Rules …
…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…
Big Data, Tax Information and the New Oil – Paradox of Plenty?
…world in the coming years. If as the authors indicate, innovation will accelerate at an exponential rate because of computing power, digitization, and the combinatory nature of innovation. The same…
Compliance and Tax Implications
…profits, withholding taxes, application of treaties, etc. All these adverse consequences evidence the importance of companies operating in Brazil (or with business involving Brazilian companies) having a strict compliance program….