The decision of the CJEU in Republic of Austria v Federal Republic of Germany (Case C-648/15) on 12 September 2017 is a landmark decision in tax treaty dispute resolution. Han Verhagen raised…
In March I blogged about the first OECD draft guidance on the allocation of profits to commissionaire and other PE’s. Looking at the June OECD draft, further ideas have come up as to why the…
As widely reported, the signing ceremony of the Multilateral Convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting ("MLI") took place on 7 June 2017, in…
Limited Liability Companies have become one of the most common forms of business organisation in the United States. Their main attraction is a combination of limited liability for LLC members and…
The objective of the EU Merger Directive (“MD”) is to remove tax obstacles to cross-border restructuring operations while safeguarding the financial interests of the Member States.[1] In aligning…
This contribution lays down a general plan for what the EU should do in order to attain a harmonized set of norms regulating the allocation of taxing rights among Member States and in the relation…
Google’s international corporate structure and operating model has featured significantly in the political and legal debate about the taxation of multinational companies, particularly in the…
On 22 June 2017, the OECD released for public comment the revised discussion draft on the application of the profit split method, which intends to continue the work developed in the OECD Transfer…
On June 7, 2017, India joined more than 65 countries in signing the OECD’s Multilateral Instrument to implement tax treaty-related base erosion and profit shifting (BEPS) recommendations. The…
