The first part of this blog post addressed the incompatibility of the anti-hybrid rule proposed by the OECD to the source state ("primary response"), which restricts the right to deduct the payments…
On August 5, 2015 Grant Thornton (GT) published their annual International Business Report, a global "mid market survey covering more than 10,000 companies in 35 economies”. Unfortunately, their…
With the declared aim of curbing cross-border tax arbitrage practiced with hybrid financial instruments, the OECD recommended, in Action 2 of the BEPS project, the adoption of anti-hybrid rules,…
In line with BEPS Action 12, the Brazilian President enacted, on July 21, 2015, the Provisional Measure ("MP") no. 685, creating the obligation for taxpayers to disclose aggressive tax plannings…
Attacking Profit Shifting by Prof. Jeffery Kadet (Abstract) In recent years the financial press has turned increasing attention to MNCs that shift income to low taxed jurisdictions overseas in order…
Dr. Andrew P. Morriss is Dean & Anthony G. Buzbee Dean’s Endowed Chairholder, Texas A&M University School of Law; Drew Estes is a JD/MBA Candidate, Class of 2016, University of Alabama. Excerpted…
What is going on in the corporate tax world? In 2013 I predicted BEPS would be a success, at least based on the press release to be issued by OECD and G20 on January 1, 2016. I have always been a…
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,…
Part 1 of the Report to G20 Development Working group (DWG) on the impact of BEPS in Low Income countries (LICs), dated July 2014, listed in its Section 6: Other High priority BEPS Issues for…
