OECD

This contribution analyzes the recent instability and uncertainty affecting the international tax landscape as of mid-2025 and identifies the key items to monitor regarding the evolution of the…

The Luxembourg High Administrative Court has rejected an appeal against a first instance decision that a holding company resident in Luxembourg had no permanent establishment in Malaysia within…

On 12 December 2022, Zbyněk Stanjura, Minister for Finance of Czechia, in representation of the EU Council, announced the implementation of the OECD Pillar Two in Europe in this way: “I am very…

Maarten de Wilde[1] and Ciska Wisman[2]SummaryIn this contribution, the authors operationalize a concrete numerical example to explain why all top-up tax variants under the EU Pillar Two Directive…

IntroductionOn 22 May we delivered an opening address on the current practical challenges of dispute prevention and resolution at the International Tax Dispute Day organized in Singapore by the Tax…

Transfer pricing adjustments under Article 9 of the model treaties are the most common form of dispute that is dealt with under the mutual agreement procedure. It is for this reason that the OECD…

*This post was first published on the website of Maastricht University*   In recent weeks the tax world gave a lot of attention to how President Trump blew up some serious advancements in…

"When I use a word," Humpty Dumpty said in rather a scornful tone, " it means just what I choose it to mean, neither more nor less." (Lewis Carroll, Alice through the Looking Glass) Prior to the OECD…

Summary While the U.S. has pulled out from the Global Tax Deal early 2025, threatening taking countermeasures, the latest batch of Inclusive Framework (IF) documents state several times that the IF…