1. Introduction
The ability to stimulate economic activity and to attract foreign capital and investments through national tax policies has been known for many centuries. It was in the middle of the…
We are glad to announce that Dr Giorgio Beretta has joined the Kluwer International Tax Blog’s team as an editor, responsible for the new section of the blog dedicated to VAT/GST and indirect…
Purpose of the blog
The purpose of the blog, which is slightly futuristic, is to discuss whether countries will still compete with one another to attract activities in their jurisdiction post-Pillar…
The purpose of this short contribution is to shed some light on the discussion regarding an Uber drivers’ qualification – whether they should be considered employees or independent contractors. If…
1. Purpose of the blog
This contribution is a follow up to the previous contribution of the author. The objective is to address the tentative impact of the Pillar I debate on decentralized MNE…
1. Purpose of the contribution
The purpose of this contribution is to address the impact of the Pillar I debate on principal structures or centralized business models. The tentative assessment will…
Purpose of the blog
The purpose of this blog is to address whether the transactional profit split method (TPSM) applies to centralized business models operated by multinational enterprises (MNEs)…
Corresponding adjustments and the MAP process
When the price charged for goods or services sold between related parties is not in accordance with the arm’s length principle, Article 9(1) of the OECD…
1. Purpose of the blog
Intra-group guarantees are usually used by companies within the same multinational enterprise to obtain beneficial conditions for funding arrangements. For instance, lower…
