Johann Müller

Denmark accepted all MLI articles dealing with PEs, but what does that actually mean?  Reading the MLI itself leaves one somewhat bewildered, being thrown back and forth between a variety of articles…

On 10 September Wolters Kluwer organized an interesting discussion on Permanent Establishments. The discussion was led by 3 panelists, Tamara Schwärzler (PwC Switzerland); Arvid A. Skaar (Norwegian…

In the introductory blog to this series, I talked about how many local files do not look like the OECD documentation requirements and that it is probably the consequence of pre-existing files being …

This is a short series of blogs on transfer pricing documentation: what I have seen over the years, how it does (not) align with OECD documentation requirements, and thoughts on possible improvements…

As we approach the halfway mark between the 2018 IFA conference in Seoul and the 2019 one in London, I want to clear up some issues around “Business” as in stakeholders in tax discussions…

It is 30 December and 2 MNEs contact me about my YouTube videos on uploading Country by Country Reports (CbCRs); they need help.  In the week of New Year, I helped taxpayers in Bermuda, Belgium,…

The problem “Please tell me what the header is, I don’t know what the namespace for multiple schemas should be.”  It seemed like a reasonable question, but I never got the answer.  The same fate…

In March I blogged about the first OECD draft guidance on the allocation of profits to commissionaire and other PE’s.  Looking at the June OECD draft, further ideas have come up as to why the…

On 23 May the OECD published a Public Discussion Draft on Implementation Guidance on Hard-to-Value intangibles (HTVIs).  Comments are due by 30 June 2017, so hurry. 1.    Introduction All guidance by…