Tax Avoidance

Jakob Bundgaard (CORIT advisory)

Darwin & Corporate Taxation – Has the Evolution of the Economy Killed the Basis for Corporate Taxation?

November 23, 2015

Written by Associate Professor, PhD, Michael Tell, Department of Law, Copenhagen Business School and Technical Advisor, CORIT Advisory. Darwin’s theory of evolution states that complex creatures…

Jonathan Schwarz (Temple Tax Chambers; King’s College London)

Are legal rights irrelevant for transfer pricing after BEPS Actions 8, 9 and 10?

November 15, 2015

The longstanding view on application of the arm’s length principle is that it is generally based on a comparison of the conditions in a controlled transaction with the conditions in transactions…

Raymond Luja (Maastricht University)

Could I Please Get a Fiat for the Price of my Frappuccino?

October 21, 2015

Today the European Commission released its first set of decisions on corporate tax rulings, which it has investigated for over a year. Starbucks Manufacturing EMEA and Fiat Finance and Trade were the…

Johann Müller (International tax professional)

News from "the other tax club"

October 21, 2015

It is the annual Session of the UN Committee of Experts on International Cooperation in Tax Matters. This Ad Hoc subsidiary body of the Economic and Social Council of the UN (ECOSOC) is responsible…

Luis Schoueri (University of Sao Paulo; Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados) , Ricardo André Galendi Júnior (Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados)

The BEPS Proposals on Intangibles: The Guidelines in Breach of the Convention

October 19, 2015

As from the first BEPS proposals with respect to intangibles, it has been considered that the Arm’s Length Standard (“ALS”) is “slowly but surely being relegated to the back seat” of the OECD…

Emanuela Matei (Mircea and Partners Law Firm)

Same Same But Different. A misunderstanding of the EU tax jurisprudence with possible negative spill-over effects on the BEPS recommendations.

October 15, 2015

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…

Guillermo O. Teijeiro (Bomchil)

Tax evasion and money laundering: The “Whole of Government” OECD Approach

September 24, 2015

In a globalized economy, financial crimes --including tax crimes-- threaten the strategic, political and economic interest of developed and developing countries as well, and undermine confidence in…

Luis Schoueri (University of Sao Paulo; Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados)

Inclusions and Adjustments under Article 9: is further consensus possible?

September 22, 2015

In the last few months I have been deeply committed with the Klaus Vogel Lecture, which will be held in September 25, 2015, in the Vienna University of Economics and Business (see invitation here). I…

Jonathan Schwarz (Temple Tax Chambers; King’s College London)

Multilateral Tax Treaty: if we build it, will they come?

September 5, 2015

In many respects a multilateral tax treaty represents an utopian view of international tax law: a wide consensus among nation states to submit themselves to a common set of rules that govern the…