OECD

The OECD BEPS project was kicked off by the observation that the interaction of domestic tax systems sometimes leads to an overlap, resulting in double taxation as well as gaps, which result in an…

That day in November 2012 It was 5 November 2012 when G20 Finance Ministers asked for a report on the root-causes of Base Erosion and Profit Shifting, by their next meeting in February 2013…

Model tax treaties do matter. The OECD and UN Models constitute precedent books with standard clauses that contracting states can follow or adapt to suit their particular circumstances. The US Model…

(“Every in-house tax department should have their own IT/Financial systems capacity” – JHM, TP Minds London, 2015.) The unexpected benefit from country by reporting (“CbyC”) reporting is that tax…

Interest and penalty regimes place a high premium on correctly identifying the existence of a permanent establishment in the territory of a state. The failure to do so often means that there is no…

Howdy from Prof. Haydon Perryman and I of Texas A&M University.  This month we undertake a 2015 review of FATCA’s GIIN registrations relative to 2014.  We also include a chart at the end of this post…

The Spanish National Court has recently ruled (case no. 182/2012) that a Spanish affiliate of Dell that sold Dell computers in Spain under a commissionaire agreement with Dell Ireland constituted a…

Written by Associate Professor, PhD, Michael Tell, Department of Law, Copenhagen Business School and Technical Advisor, CORIT Advisory. Darwin’s theory of evolution states that complex creatures…

The longstanding view on application of the arm’s length principle is that it is generally based on a comparison of the conditions in a controlled transaction with the conditions in transactions…