BEPS

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,…

Among the main issues the BEPS project intends to address is the phenomenon of “double non-taxation”. It is a term that is used quite frequently nowadays; primarily in order to describe situations…

In mid-November, the Republican majority in the US House of Representatives has passed its version of the Tax Cuts and Jobs Act bill. Last Saturday, the Senate has followed suit and has cast a 51:49…

Recently, a special Mexican Circuit Court (“the Court”) issued a ruling regarding the interpretation of an international convention (the North American Free Trade Agreement or “NAFTA”) which may…

Taxation of the digital economy featured in discussion on the implementation of the OECD/G20 BEPS action items at the annual conference of the Canadian Tax Foundation in Toronto on 21 November 2017…

The Argentine 2017 proposed income tax amendment: A misstep averted just before reaching the edge of the cliff 1. Background 1.1. International context The post-BEPS international tax scenario shows…

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 regards to the title of this post, the Ways & Means version of international tax reform moves toward a territorial regime of granting an exemption for foreign profits but then derogates from the…

India’s Income Tax Appellate Tribunal, Bangalore on September 28, 2017, handed down a decision in which it noted that the profits of a foreign company based in Saudi Arabia cannot be taxed in India…