Last month my blog discussed the questions relating to corporate residence and article 4(1) of the UK-US Double Tax Treaty raised in G E Financial Investments v HMRC [2021] UKFTT 210 (TC). This…
On 20 May, 2021 the first Webinar of IFA’s online series “A conversation on International Tax Practice” was held. Chaired by Robert Danon (Chair IFA Permanent Scientific Committee), global experts…
When is a taxpayer a resident of a contracting state for purposes of a tax treaty? The decades old definition in article 4(1) of the OECD Model that ‘“resident of a Contracting State” means any…
Today, there is an exponential increase in new forms of commercialization of goods and the provision of services that make use of digital platforms. This situation is altering the functioning of the…
Welcome to the second tax post in the series of International Law Talk. During a series of podcasts, Wolters Kluwer will bring you the latest news and industry insights from thought leaders and…
1. Background
During the 21st Session of the UN Committee of Experts on International Cooperation in Tax Matters, the relevant members decided to include a new draft - Art. 12B on Automated Digital…
Summary
There might be a leak in the OECD’s global minimum tax proposals (GLOBE; Pillar Two). To address the remaining challenges of base erosion and profit shifting (BEPS) by large multinational…
There's something about OECD's Pillar One. For some years now, the world has been under the spell of a new system of taxation of companies that make profits in countries without taking root there in…
As the Blueprint on Pillar I illustrates, the political and technical complexities inherent to the solution sought by OECD are of such magnitude, that such a sole fact opens the window to an…
