Due to an amendment of the EU Parent-Subsidiary Directive, the EU Member States must include a common minimum anti-abuse provision in their legislation by 31 December 2015 at the latest.
The common…
International theory and practice
In examining the economic considerations that should be taken into account for the legal framework for the eventual peace agreements in Colombia, I found that…
Article 7(1) of the OECD model treaty is perhaps the most important rule regulating the international taxation of business. It sets out the fundamental basis on which businesses are taxed, that is,…
BEPS-Project? CFC rules and transfer pricing? Treaty abuse and dispute resolution? Why bother for such complicated things? Greece has a “perfect” solution against base erosion and profit shifting…
Action 6 of the BEPS Action plan is aimed at (i) developing Model Treaty provisions and recommendations on the design of domestic tax rules to prevent the granting of treaty benefit in inappropriate…
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…
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…
Reform Path Forward for China’s Tax Law Reform
The observation on the current fiscal and tax system helps China to improve and execute a profound tax system to realize goals proposed in The…
