1. Purpose of the blog
This contribution is a follow up to the previous contribution of the author. The objective is to address the tentative impact of the Pillar I debate on decentralized MNE…
The Canadian Federal Court of Appeal has upheld the Tax Court of Canada decision in Canada v. Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 (CanLII). The case is of some significance because the…
1. Purpose of the contribution
The purpose of this contribution is to address the impact of the Pillar I debate on principal structures or centralized business models. The tentative assessment will…
This is not a technical commentary. It does not react to a ‘new’ development or case. But these comments do try to focus on understated rudiments of the present international tax debate which may…
The magnitude of the so-called Pillar 1 of the OECD Unified Approach to address the tax challenges of the digitalization of the economy should not be underestimated, especially after the endorsement…
Revised transfer pricing legislation set out in the Finance Act 2019 (No 45 of 2019), sections 24 to 27, represents a radical shift in the Irish approach to this area of international tax law…
Two cases, currently before different courts highlight long-standing questions around the attribution of profits to permanent establishments. Irish and United Kingdom law on the attribution of…
In 2017, Brazil sent a formal request to the Organisation for Economic Co-operation and Development (“OECD”) to become one of its members. It seems that this decision -- made by the economic team of…
May linking rules related to hybrid financial instruments be incompatible with the EU Fundamental freedoms? And with Article 24 (4) OECD MC? What about treaty override?
It is no secret that hybrid…
