BEPS

A critical appraisal of the EU Switch Over Rule and the Indian Equalization Levy At present, it is unavoidable to recognize that the international tax scenario is in transition to a much more inter…

The OECD BEPS project was kicked off by the observation that the interaction of domestic tax systems sometimes leads to an overlap, resulting in double taxation as well as gaps, which result in an…

That day in November 2012 It was 5 November 2012 when G20 Finance Ministers asked for a report on the root-causes of Base Erosion and Profit Shifting, by their next meeting in February 2013…

India’s 2016 Budget is proof that the Government is not only aware of major tax developments taking place globally, but is also sincere in bringing the country’s municipal tax system into line with…

What do these two things have in common?  Dr. Andrew P. Morriss, Dean & Anthony G. Buzbee Dean's Endowed Chair, Texas A&M School of Law explains In 1998, seven US heavy-duty diesel engine (HDDE)…

Model tax treaties do matter. The OECD and UN Models constitute precedent books with standard clauses that contracting states can follow or adapt to suit their particular circumstances. The US Model…

(“Every in-house tax department should have their own IT/Financial systems capacity” – JHM, TP Minds London, 2015.) The unexpected benefit from country by reporting (“CbyC”) reporting is that tax…

MNC profit shifting has received major attention over the past few years. Total earnings stockpiled overseas are now reported to be in excess of $2 trillion. One of the authors published a technical…

(about the switch-over clause in the ATA Directive) In order to combat BEPS, the European Commission is proposing to start taxing low taxed non-EU income. That sounds reasonable, but the consequence…