Johann Müller

So what were the other discussions at the UN from 19 to 23 October this year?  One of the main topics is the continuing work on a withholding tax on technical services.  The reason for developing…

It is the annual Session of the UN Committee of Experts on International Cooperation in Tax Matters.  This Ad Hoc subsidiary body of the Economic and Social Council of the UN (ECOSOC) is responsible…

Today at 2 pm the OECD announced the final BEPS action plan on a live webstreamed news conference. Though this was very high level, it did not seem as though the final versions of the 15 action plans…

This is another lone voice cry in the wilderness – I am getting used to that. By 9 September 2015, anyone who has an opinion about further corporate tax transparency in Europe, are invited to file it…

On 17 June 2015, the Commission adopted a plan to relaunch the 3CTB (Common Consolidated Corporate Tax Base), a common system for calculating the tax base of businesses operating in the EU.  Except,…

Whoever thinks that a resident company's income is protected from taxation in countries where it has no PE, is in for a rude awakening; it is not. The allowance for CFC rules in the OECD Model…

I ”grew up” believing that publications of the OECD are the bibles of taxation.  They are scientific master pieces, tell you what to do and, like other holy books, are often open for multiple…

On 14 August 2014 the Philippines Court of Tax Appeals (“CTA”) decided case no. 1041 regarding Goodyear. However, the underlying issue was already decided in March 2013 by the same court in case no…