Massive leaks of information on offshore activity like the Panama Papers illustrate the need for an enhanced global tax cooperation with an improved and deeper interjurisdictional information sharing…
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…
Model tax treaties do matter. The OECD and UN Models constitute precedent books with standard clauses that contracting states can follow or adapt to suit their particular circumstances. The US Model…
(about the switch-over clause in the ATA Directive)
In order to combat BEPS, the European Commission is proposing to start taxing low taxed non-EU income. That sounds reasonable, but the consequence…
In 2015, people around the globe celebrated the 800th anniversary of the Magna Carta Libertatum, considered to be the first constitutional-like document that established restrictions on a sovereign’s…
Written by Associate Professor, PhD, Michael Tell, Department of Law, Copenhagen Business School and Technical Advisor, CORIT Advisory.
Darwin’s theory of evolution states that complex creatures…
The longstanding view on application of the arm’s length principle is that it is generally based on a comparison of the conditions in a controlled transaction with the conditions in transactions…
An open door for emerging economies or the beginning of the end in international tax co-ordination
In an article published earlier this year,[1. Teijeiro, Opening the Pandora’s Box in the…
As from the first BEPS proposals with respect to intangibles, it has been considered that the Arm’s Length Standard (“ALS”) is “slowly but surely being relegated to the back seat” of the OECD…
