Lessons to LatAm from recent developments of one of the oldest tax treaty networks in the region
The final outcome of Action 6, BEPS, posses the query of adopting the principal purpose test (PPT)…
When the EU Anti Tax Avoidance Package was launched by the European Commission, a Study on Structures of Aggressive Tax Planning and Indicators was released simultaneously as Taxation papers –…
MNC profit shifting has received major attention over the past few years. Total earnings stockpiled overseas are now reported to be in excess of $2 trillion. One of the authors published a technical…
I. Introduction
Shall international tax planning decrease after the implementation of BEPS? The reply is "depends" by virtue of the subject’s exposure to several variables.
Obviously, one should…
The IRS issued Notice 16-08 announcing that it will extend timelines or modify four elements of FATCA -
(1) modify the date for submitting to the IRS the preexisting account certifications required…
The Indian Ministry of Finance released last month draft guidance on applying the “place of effective management” (POEM) test to determine tax residence of companies. The guidance came almost eight…
On January 15, 2016, in a joint (bi-partisan) letter of Senate Finance Committee Republicans and Democrats to US Treasury, one that will certainly be of interest to our friends at Wolters Kluwer (a…
In his last State of the Union speech on January 13, 2016 Obama put it quite clear: “The United States of America is the most powerful nation on Earth. Period. It's not even close.”
With this…
"Your net worth to the world is usually determined by what remains after your bad habits are subtracted from your good ones." Benjamin Franklin
Organisations generally, when starting a business in…
