The scope of the present article will be narrow. The aim is to point out a misinterpretation of the Cadbury ruling, which might have caused a flawed theory of the compatibility of certain CFC regimes…
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 DTT’s signed by the LATAM countries generally follow the rule included both in the OECD and UN Tax-Convention Models. Article 24 Section 1 states that “nationals of a contracting state shall not…
Tax treaty rules to resolve the dual residence of persons other than individuals have been consistent since the 1963 OECD draft convention. Such dual residence in resolved by Article 4(3) of the OECD…
Two years ago, the OECD’s BEPS project started with the goal that Multinational Enterprises pay their fair share of taxes. There was some hope that unfair tax competition, especially in the form of…
An issue of topical interest for tax administrations in the heat of the BEPS Plan, examining the existence of a PE does not seem to be on the agenda of Brazilian authorities. In a ruling from June,…
