More and more soccer players hit the newspapers because they are not just creative in the soccer stadiums but also in dealing with their tax returns. Recently we have seen the press reporting on…
General
On February 9, 2017, the Court of Justice of the European Union (‘CJEU’) rendered its decision in the X v Staatssecretaris van Financiën (‘X’). The case concerned the possibility of…
Introduction and EU law applicable
On 8 March 2017 the Court of Justice of the European Union (hereafter “CJ”) delivered its decision in the Case C-448/15, Wereldhave, dealing with the interpretation…
Lower energy cost is a major factor for U.S. manufacturers … to be able to offer on par production costs to China, and 10 percent to 20 percent lower costs than European manufacture.
I’ve been remiss…
There are several misconceptions in international taxation, some of them more pervasive than others. Many are often repeated by speakers at tax conferences without being contradicted.
The first is…
On September 14th, 2016, the Brazilian Federal Revenue Service (“RFB”) published the Normative Instruction RFB No. 1,658/2016, which included legal entities incorporated as holding companies in…
Tax practitioner’s in the northern hemisphere taking their summer holidays may well have included the OECD discussion draft of 5 July 2016 on the attribution of profits to permanent establishments as…
Harmonisation of the efforts to discourage tax avoidance in the EU
Recently, besides the objective of maintaining a balanced allocation1 (a reflection of the principle of territoriality), the…
The attribution of profits to a permanent establishment is already a complex issue with at least three separate regimes in the tax treaty context- the OECD Authorised Approach under the 2010 OECD…
