Two cases, currently before different courts highlight long-standing questions around the attribution of profits to permanent establishments. Irish and United Kingdom law on the attribution of…
In 2017, Brazil sent a formal request to the Organisation for Economic Co-operation and Development (“OECD”) to become one of its members. It seems that this decision -- made by the economic team of…
We are happy to inform you that the latest issue of the journal is now available. It is a special issue on transfer pricing in the digital economy. It combines academics and practitioners’ analysis…
We applaud the OECD’s 15-year effort since its 2005 publication of E-commerce: Transfer Pricing and Business Profits Taxation to address the challenges arising from the digitalization of…
In my International Taxation class tomorrow (October 10th) we are going to discuss the OECD's “Unified Approach” released a day earlier on October 9, 2019. Given the keen interest generated by…
The General Court of the European Union has issued two awaited rulings in the Starbucks[1] and Fiat[2] cases. The length and the depth of the analysis made by the judges of the General Court should…
William Byrnes, Texas A&M University School of Law* (33-page draft research available on SSRN)
Howdy! Earlier today the General Court of the European Court of Justice (EGC) sided with Starbucks’…
Nothing changed but the change
Despite several changes were introduced to Chapter I and Chapter VI of the 2017 OECD Guidelines on intangibles in accordance with Actions 8-10 BEPS Final Reports to…
Purpose of the blog
The purpose of this blog is to address whether the transactional profit split method (TPSM) applies to centralized business models operated by multinational enterprises (MNEs)…
