BEPS

“A camel is an animal designed by a committee” – Anonymous In launching the BEPS programme in 2013, the OECD warned that replacement of the current consensus-based framework by unilateral measures,…

The recent appearance of the Multilateral Convention to Implement Tax treaty Related measures to prevent BEPS (the Multilateral BEPS Convention or the Convention)[1] rounded up the implementation of…

Publication of text of The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention) by the OECD on 24 November 2016 is one of the…

There are many things in life that we take for certainties, which are not, e.g. that it was the Scots that invented whiskey, the French champagne, or the Italians pizza.  All not necessarily true…

Brazil is known for its unique transfer pricing legislation. While in most countries the use of comparables is central for the application of the transfer pricing methods, the Brazilian system has…

The transition from bilateralism to multilateralism in regard of international law-making seems to be a relentless work in progress. Nobody contests that multilateralism would be – legally speaking –…

The OECD has today published details of the peer review and monitoring process of the Mutual Agreement Procedure (MAP) under Action 14 of the BEPS Action Plan. The framework includes the terms of…

As previously reported on this Blog the EU Anti-Tax Avoidance Package was presented on 28th January 2016. The package included: -          Recommendation on Tax Treaties -          Amended Directive…

On September 14th, 2016, the Brazilian Federal Revenue Service (“RFB”) published the Normative Instruction RFB No. 1,658/2016, which included legal entities incorporated as holding companies in…