A thought-provoking and insightful series of papers on taxpayer rights have just been published in the latest edition of The Tax Lawyer,[1] published by the American Bar Association Section of…
“Mirror, mirror, on the wall, who’s the fairest of them all?” – Brothers Grimm, “Snow White”
Where it all started
Tax evolved like many things in the world we experience today. Taxes were already…
Introduction
While tax legislation is subject to continuous changes, tax treaties are an interesting tool whereby Contracting States offer investors some degree of legal certainty, especially where…
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…
“I know there's a proverb which that says 'To err is human,' but a human error is nothing to what a computer can do if it tries.” - Agatha Christie, Hallowe'en Party
The now
Have you ever wondered…
Probably without noticing it, Colombia did not take into account that signing the recent DTT with France would allow some treaty-covered taxpayers to claim Most-Favoured-Nation (MFN) protection.
Some…
When UK voters went to the polls on 23 June 2016 and voted by a slim majority to leave the European Union, few of them had in mind the impact on taxation. Future generations are unlikely to view it…
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…
I recently participated in a seminar on tax & innovation in Naples, my home town where I stay often to arrange personal issues, which has a sparkling start-up community, in an increasingly conducive…
