Introduction
Recently captive insurance arrangements have been scrutinized all over the world by tax authorities as they are believed to be vehicles that encourage profit shifting. The OECD, in the…
Introduction
One of the advantages multinational groups enjoy over standalone companies is that their members have access to each other’s resources (such as, e.g., funding). In particular, less…
Introduction
One of the most controversial topics of transfer pricing, in today's multinational world, is the pricing of intercompany financial transactions. The 2017 OECD transfer pricing guidelines…
The Existing Framework: Nexus and Profit Attribution Rules
Under the current Double Taxation Avoidance Agreement (DTAA) framework, business profits are in principle taxable in the State of residence…
Introduction
The financial crisis had made multinational enterprises (MNE) look inward for funding options, as external sources of capital were not readily available. Among various intra group…
