This has been an interesting session and for those who were not there, I am sure that the essence is reported elsewhere in the international tax press. The deliberations lead me to the following…
On June 27, 2016 the EU Commission published the long awaited Starbucks State Aid decision (see here). The EU Commission’s decision challenges the outcome of the Advanced Pricing Agreement (APA)…
1. The Tendency
We live in a time where the media, politicians, NGOs and activists increasingly are preoccupied with international tax matters. A simultaneous preoccupation is observed among the OECD…
In highly dramatic fashion the French tax authorities and IT specialists raided Google's headquarters and McDonalds. I don't own Google stock. I'm not in favor of Google's near monopoly on search …
The OECD BEPS project was kicked off by the observation that the interaction of domestic tax systems sometimes leads to an overlap, resulting in double taxation as well as gaps, which result in an…
On January 15, 2016, in a joint (bi-partisan) letter of Senate Finance Committee Republicans and Democrats to US Treasury, one that will certainly be of interest to our friends at Wolters Kluwer (a…
In many respects a multilateral tax treaty represents an utopian view of international tax law: a wide consensus among nation states to submit themselves to a common set of rules that govern the…
On August 12, 2015 the IRS released two final revenue procedures impacting the U.S. transfer pricing regime. Revenue Procedure 2015-40 concerns the protocols and procedures for requesting assistance…
Let’s go back a few weeks, to March 18, 2015. The EU Commission announces its much heralded Tax Transparency package. The package contains a surprise element: the link to the Code of Conduct Report…
