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…
When internationally mobile workers retire, they look to Art 18 of the OECD Model tax treaty to determine their tax treatment if they are private sector workers. Government workers look to Art 19…
I ”grew up” believing that publications of the OECD are the bibles of taxation. They are scientific master pieces, tell you what to do and, like other holy books, are often open for multiple…
“You never want a serious crisis to go to waste”, Rahm Emanuel, Chicago Mayor (and former Obama White House chief-of-staff)
Fundamental reforms are always controversial and the G20/OECD hard-pressed…
On 11 February 2015 a US District Court found that the US Internal Revenue Service disclosed false tax return information to the Japanese National Tax Administration contrary to the Japan-US tax…
On 14 August 2014 the Philippines Court of Tax Appeals (“CTA”) decided case no. 1041 regarding Goodyear. However, the underlying issue was already decided in March 2013 by the same court in case no…
An issue of topical interest for tax administrations in the heat of the BEPS Plan, examining the existence of a PE does not seem to be on the agenda of Brazilian authorities. In a ruling from June,…
