Action 6 of the BEPS Action plan is aimed at (i) developing Model Treaty provisions and recommendations on the design of domestic tax rules to prevent the granting of treaty benefit in inappropriate…
Whoever thinks that a resident company's income is protected from taxation in countries where it has no PE, is in for a rude awakening; it is not. The allowance for CFC rules in the OECD Model…
There are a lot of opinions on multinationals and their tax practices. One conventional perception is that multinationals have a general tax advantage over their domestic competitors as their…
This contribution is aimed at surveying the interaction and reciprocal influence between the OECD-G20 BEPS Action Plan (the BEPS Plan), on one hand, and contemporary tax developments occurred in the…
The claim for the so-called “single taxation principle”, in spite of its doubtful general acceptance, seems to have been acknowledged by the OECD, which has moved from a position whereby countries…
After the first post on BEPS, I decided to go laterally and approach an issue that may resonate to many tax practitioners but unfortunately is not so widely discussed perhaps because of its…
It is well known that case law from the European Court of Justice (ECJ) imposes limitations on the application of anti-avoidance rules by Member States. Accordingly, it is of vital importance that…
In July 2013, the OECD published its Action Plan on Base Erosion and Profit Shifting, aimed at ensuring the coherence of corporate income taxation at the international level. Action 3 of the Plan…
I ”grew up” believing that publications of the OECD are the bibles of taxation. They are scientific master pieces, tell you what to do and, like other holy books, are often open for multiple…
