This is a short series of blogs on transfer pricing documentation: what I have seen over the years, how it does (not) align with OECD documentation requirements, and thoughts on possible improvements…
Mutual agreement procedure (MAP) pursuant to article 25 of the OECD and UN Model treaties imposes obligations on tax administrations. Inadequacies in the performance of these obligations has been the…
Taxation of the digital economy has become a war in the post-BEPS world. As with any war, there are more or less clear rivals and there will be of course winners and losers. It goes without saying…
Corresponding adjustments and the MAP process
When the price charged for goods or services sold between related parties is not in accordance with the arm’s length principle, Article 9(1) of the OECD…
Taxation of the digital economy is one of the more difficult and contentious issues in international taxation. There are several strands to this complexity. One strand is profit attribution for…
In 1789, Benjamin Franklin wrote in a letter to French scientist Jean-Baptiste Leroy: “Our new Constitution is now established, and has an appearance that promises permanency; but in this world…
The High Court of Kenya gave judgement on 15 March 2019 on a challenge to the validity of the Kenyan-Mauritius double tax treaty in Tax Justice Network- Africa v Kenya Revenue Authority and others. …
The proposal for upholding a minimum effective tax rate on corporate profits, on which the OECD Inclusive Framework recently invited comments, has received a lot of criticism. A minimum tax would…
Groundbreaking decision, landmark case, a milestone in EU case law, disappointing surprise: there are different ways to refer to the European Court of Justice (ECJ) judgments issued on February 26,…
