Along the last 15 years, the discussion of tax planning in Brazil evolved significantly, changing from a very formalist approach to an approach that scares taxpayers by its aggressiveness and lack of…
Whoever thinks that a resident company's income is protected from taxation in countries where it has no PE, is in for a rude awakening; it is not. The allowance for CFC rules in the OECD Model…
There are a lot of opinions on multinationals and their tax practices. One conventional perception is that multinationals have a general tax advantage over their domestic competitors as their…
Following my latest post on the Court of Justice’s decision in Commission v UK (C-172/13, ECLI:EU:C:2015:50), I want to turn in this comment on the related issue of currency losses, which was…
This contribution is aimed at surveying the interaction and reciprocal influence between the OECD-G20 BEPS Action Plan (the BEPS Plan), on one hand, and contemporary tax developments occurred in the…
The ministers signed a Supplementary Agreement (SA) amending the French-German Double Taxation Convention. The SA simplifies the taxation for pensioners by attributing the exclusive taxing right for…
The claim for the so-called “single taxation principle”, in spite of its doubtful general acceptance, seems to have been acknowledged by the OECD, which has moved from a position whereby countries…
On April 8th, the Labour Party has pledged to abolish the British preferential tax rules for non-domiciled individuals (non-doms), should it win the general election on May 7th. This long overdue…
The world is following with attention the developments of one of the major all-time corruption scandals, involving one of the symbols of the Brazilian economy, Petrobras. If it was not enough fuzz,…
