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…
On June 27, 2016 the EU Commission published the long awaited Starbucks State Aid decision (see here). The EU Commission’s decision challenges the outcome of the Advanced Pricing Agreement (APA)…
“Improper and plainly undermines legal certainty and the rule of law.” This is how four U.S. senators – including the Chairman and Ranking Member of the U.S. Senate Finance Committee – recently…
1. The Tendency
We live in a time where the media, politicians, NGOs and activists increasingly are preoccupied with international tax matters. A simultaneous preoccupation is observed among the OECD…
In highly dramatic fashion the French tax authorities and IT specialists raided Google's headquarters and McDonalds. I don't own Google stock. I'm not in favor of Google's near monopoly on search …
George Orwell's parable, Animal Farm, offers insights on political and governmental institutions that bear revisiting from time to time. BEPS Action 6 with the broad title “Prevent treaty abuse” has…
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…
The OECD BEPS project was kicked off by the observation that the interaction of domestic tax systems sometimes leads to an overlap, resulting in double taxation as well as gaps, which result in an…
What do these two things have in common? Dr. Andrew P. Morriss, Dean & Anthony G. Buzbee Dean's Endowed Chair, Texas A&M School of Law explains
In 1998, seven US heavy-duty diesel engine (HDDE)…
