Haydon Perryman’s exclamation this month, in the form of the above title, underlies that the FATCA GIIN update as of August 2015 is that there is little to update in terms of new GIINs. From July…
On august 7, 2015, OECD released its Update on Voluntary Disclosure Programmes: A pathway to tax compliance, a renewed edition of the survey published in 2010, aimed at providing guidance to…
The case brings about the opportunity to fill a gap in the Norwegian tax law. In order to determine the fiscal residence of a corporation, the current formula stipulated by art. 2(2) Tax Act uses the…
The first part of this blog post addressed the incompatibility of the anti-hybrid rule proposed by the OECD to the source state ("primary response"), which restricts the right to deduct the payments…
On August 5, 2015 Grant Thornton (GT) published their annual International Business Report, a global "mid market survey covering more than 10,000 companies in 35 economies”. Unfortunately, their…
With the declared aim of curbing cross-border tax arbitrage practiced with hybrid financial instruments, the OECD recommended, in Action 2 of the BEPS project, the adoption of anti-hybrid rules,…
The services permanent establishment concept is perhaps the most noteworthy contribution to tax treaties provided by the UN model. The tax treaty concluded by South Africa and the United States in…
In line with BEPS Action 12, the Brazilian President enacted, on July 21, 2015, the Provisional Measure ("MP") no. 685, creating the obligation for taxpayers to disclose aggressive tax plannings…
In our previous blog we were discussing issues of non-discrimination on the basis of Nationality (article 24.1 MOCDE). Today, it is relevant to point out the fact that the idea of non-discrimination…
