When is a taxpayer a resident of a contracting state for purposes of a tax treaty? The decades old definition in article 4(1) of the OECD Model that ‘“resident of a Contracting State” means any…
When the UK introduced its diverted profits tax, I was telephoned by a lawyer at the US Treasury. He wanted to know whether the “just and reasonable” apportionment of profits, in certain…
One objective of Estonian Tax and Customs Board (ETCB) is to provide simple and convenient services to taxpayers. To achieve this, the ETCB has invested significant amount of resources to enable…
