1. Carve-out of financial services from the scope of Amount A
According to the Report on the Pillar One Blueprint,[1] the proposed scope of Amount A is designed to capture multinational groups that…
When the UK introduced its diverted profits tax, I was telephoned by a lawyer at the US Treasury. He wanted to know whether the “just and reasonable” apportionment of profits, in certain…
This article is the last of a series of three posts dealing with non-chargeable intra group services: Shareholder Activities, Duplicate Activities and Incidental Benefits. This post will specifically…
Introduction
Except for the unprecedented health crisis, the COVID-19 spread has generated the biggest economic and financial shock of the century across markets and cross-borders.[1] The preventive…
Duplicate activities?
Duplicate services are defined in the 2017 Transfer Pricing Guidelines (TPG) of the OECD as “activities undertaken by one group member that merely duplicate a service that…
Council Directive (EU) 2018/822 (generally known as DAC 6) expressly provides for reporting obligations concerning cross-border arrangements that present an indication of a potential risk of tax…
In my last blog, I looked at the immediate impact of Covid 19 Lockdowns on key elements of double tax treaties – residence, permanent establishment and employment income. Many tax administrations…
Shareholder activities?
As mentioned by the 2017 Transfer Pricing Guidelines (TPG) of the OECD[1], one of the two main issues relating to the analysis of transfer pricing for intra-group services, is…
Introduction
There is no divine truth about what the Arm’s Length Standard (ALS) actually means. Its content can only be determined by a decision, which can be reached by a court or by means of…
