BEPS

So what were the other discussions at the UN from 19 to 23 October this year?  One of the main topics is the continuing work on a withholding tax on technical services.  The reason for developing…

An open door for emerging economies or the beginning of the end in international tax co-ordination In an article published earlier this year,[1. Teijeiro, Opening the Pandora’s Box in the…

Both Starbucks and Fiat represent, if one listened closely to the live press release broadcast, an first salvo by the EU Commission to establish that it has the authority, under a State Aid premise,…

It is the annual Session of the UN Committee of Experts on International Cooperation in Tax Matters.  This Ad Hoc subsidiary body of the Economic and Social Council of the UN (ECOSOC) is responsible…

As from the first BEPS proposals with respect to intangibles, it has been considered that the Arm’s Length Standard (“ALS”) is “slowly but surely being relegated to the back seat” of the OECD…

The scope of the present article will be narrow. The aim is to point out a misinterpretation of the Cadbury ruling, which might have caused a flawed theory of the compatibility of certain CFC regimes…

Today at 2 pm the OECD announced the final BEPS action plan on a live webstreamed news conference. Though this was very high level, it did not seem as though the final versions of the 15 action plans…

Everyone concerned with international taxation awaits the publication of the final package of BEPS measures by the OECD on Monday 5 October 2015. While the BEPS programme addresses disparities…

In the last few months I have been deeply committed with the Klaus Vogel Lecture, which will be held in September 25, 2015, in the Vienna University of Economics and Business (see invitation here). I…