Back in 2015, my first ever blog asked Does the UK Diverted Profits Tax help or hurt BEPS? Whatever the answer, the level of complexity and the challenges it brought to UK cross-border taxation…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:
Reuven Avi-Yonah, Do Intangibles Fit BEFIT?
This article argues that the…
Executive summary:
When we look at the digital economy, we tend to think of it as a global, intangible and knowledge-driven system. However, the digital economy is not only driven by patents or…
Bram Markey – EMEA Leader Tax Controversy & Dispute Resolution at PwC Belgium
Raphaël Devroye – Transfer Pricing Manager at PwC Belgium
In a recent judgement[1], the Belgian Court of Appeal of Ghent…
“Those who cannot remember the past are condemned to repeat it” George Santayana, The Life of Reason: Reason in Common Sense (1905).
A seminar was held in Rotterdam on 18 May 2018 on “value creation”…
Taxation of the digital economy featured in discussion on the implementation of the OECD/G20 BEPS action items at the annual conference of the Canadian Tax Foundation in Toronto on 21 November 2017…
On 23 May the OECD published a Public Discussion Draft on Implementation Guidance on Hard-to-Value intangibles (HTVIs). Comments are due by 30 June 2017, so hurry.
1. Introduction
All guidance by…
Lower energy cost is a major factor for U.S. manufacturers … to be able to offer on par production costs to China, and 10 percent to 20 percent lower costs than European manufacture.
I’ve been remiss…
In a decision that offers the much-needed certainty in the tax treatment of income arising from the cross-border transfer of rights in intangibles used by Indian subsidiaries of multinational…
