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,…
The text represents the personal views of the author, which do not purport to represent the view of Poland’s Ministry of Finance.
In the judgement in X GmbH (Case C-135/17), on 26 February 2019, the…
The recent (February 2019) OECD document for public consultation introduced two proposals to address the challenges of taxation, the first one is the revised profit allocation and nexus rules in the…
Jonathan Schwarz has already briefly discussed the CJEU’s judgment in the “Danish Beneficial Ownership Cases” (C-115/16, C-118/16, C-119/16, C-299/16 and C-116/16 and C-117/16), noting that the cases…
