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…
This week, the United Kingdom Supreme Court, in a landmark decision, has ruled that a UK resident individual member of a Delaware limited liability company is entitled to credit in the UK for US tax…
Co-authored by Luís Eduardo Schoueri and Mateus Calicchio Barbosa
Spotlight was shed on transparency by the OECD’s BEPS Plan, where a set of Actions was put forward under the flag of “ensuring…
Dr. Andrew Morriss, Dean of Texas A&M University School of Law
The rapidly shifting world of international financial and tax regulation – from the OECD’s BEPS to FATCA – is reshaping the world. Many…
Article 7(1) of the OECD model treaty is perhaps the most important rule regulating the international taxation of business. It sets out the fundamental basis on which businesses are taxed, that is,…
BEPS-Project? CFC rules and transfer pricing? Treaty abuse and dispute resolution? Why bother for such complicated things? Greece has a “perfect” solution against base erosion and profit shifting…
