Welcome to the latest tax podcast in the International Law Talk series. During a series of podcasts, Wolters Kluwer will bring you the latest news and industry insights from thought leaders and…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:
Tsilly Dagan, GLoBE: The Potential Costs of Cooperation
This article argues…
It has been 60 years since publication of the OECD 1963 Draft Double Taxation Convention on Income and Capital. That model has provided the core and structure of all subsequent model double tax…
Mees Vergouwen[1]
On 21 June 2023, the Netherlands and Belgium signed a new tax treaty.[2] Part of (the protocol to) this tax treaty is a subordination clause[3] that provides that "nothing in this…
Introduction
On 8 February 2023, Mathias Cormann, Secretary-General of the OECD, hosted the OECD’s first Inclusive Forum on Carbon Mitigation Approaches (IFCMA). As its name indicates and as many…
On 28 September 2022, the Organisation for Economic Cooperation and Development (OECD) published its Bilateral Advance Pricing Arrangement Manual (BAPAM).[1] The BAPAM aims to help streamline…
“Oh, I was so happy when I was told you were in the panel!” It is always nice that someone is pleased with your presence, but this surprised me a bit. The OECD employee who made this confession had…
Even before introduction of the BEPS PPT, the UK has had purpose-based provisions in various forms, designed to limit access to treaty benefits in its double tax treaties since the 1960’s. Its…
Two years on since Chapter X of the OECD Transfer Pricing Guidelines (Chapter X) was published in February 2020, the practical transfer pricing aspects of financial transactions are due another look…