Tax Avoidance

On April 12, 2016, India’s High Court at Madras delivered a landmark ruling in favor of an anti-avoidance provision (section 94A) introduced in the Indian Income Act, in 2011, to enable the…

Massive leaks of information on offshore activity like the Panama Papers illustrate the need for an enhanced global tax cooperation with an improved and deeper interjurisdictional information sharing…

The dust has not settled yet and there is probably much more to come from this and future leaks. Investigations have started, international cooperation will be key and hopefully those that have not…

A critical appraisal of the EU Switch Over Rule and the Indian Equalization Levy At present, it is unavoidable to recognize that the international tax scenario is in transition to a much more inter…

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…

Introduction On 28 January 2016, the proposal for a council directive laying down rules against tax avoidance practices that directly affect the functioning of the internal market (the so-called ATA…

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…

(about the switch-over clause in the ATA Directive) In order to combat BEPS, the European Commission is proposing to start taxing low taxed non-EU income. That sounds reasonable, but the consequence…

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…