BEPS

Since 2013 the OECD has worked on forging a grand coalition (now 136 countries) it calls the “Inclusive Framework” around adopting the outcomes of the OECD’s Base Erosion and Profit Shifting (BEPS)…

The Canadian Federal Court of Appeal has upheld the Tax Court of Canada decision in Canada v. Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 (CanLII).   The case is of some significance because the…

Revised transfer pricing legislation set out in the Finance Act 2019 (No 45 of 2019), sections 24 to 27, represents a radical shift in the Irish approach to this area of international tax law…

Introduction In an unexpected move, the Mexican government and legislative introduced a sweeping tax reform for 2020, introducing mostly anti-abuse and anti-base erosion rules (the “Reform”). In one…

Our 14-page comments and recommendations of 14 tax professionals and academics from 11 countries raise additional issues and concerns, and propose additional recommendations to undertake a detailed…

We applaud the OECD’s 15-year effort since its 2005 publication of E-commerce: Transfer Pricing and Business Profits Taxation to address the challenges arising from the digitalization of…

Income tax rules are under great pressure internationally, because multinational enterprises, such as Apple, Facebook and McDonald’s, and rich individuals, such as Messi and Ronaldo, avoid or evade…

In my International Taxation class tomorrow (October 10th) we are going to discuss the  OECD's “Unified Approach” released a day earlier on October 9, 2019.  Given the keen interest generated by…

India recently notified a Protocol that amends the India-China tax treaty and incorporates some of the OECD recommendations put forth as part of its BEPS project. The changes would apply from the…