Globally, countries are making a concerted effort to rein in the direct tax challenges posed by the digital economy. Some of this work is directly inspired by the recommendations set out by the OECD…
One of the fascinating features of EU law is that no matter how well-established its classics may be, they are revisited over and over again. If you thought you had seen it all about preliminary…
Taxation of the digital economy remains fixed in the first position of the international tax charts, with the discussions focusing lately on the so-called Amazon tax considered to be introduced in…
Introduction
Recently captive insurance arrangements have been scrutinized all over the world by tax authorities as they are believed to be vehicles that encourage profit shifting. The OECD, in the…
I am delighted to see that my post on value creation has stimulated discussion on the fundamental thinking about international taxation. See the posts of my friends and colleagues Werner Haslehner…
In regards to the title of this post, the Ways & Means version of international tax reform moves toward a territorial regime of granting an exemption for foreign profits but then derogates from the…
The Multilateral Convention to Implement Tax treaty Related measures to prevent BEPS (the Multilateral BEPS Convention or MLI) rounded up the implementation of the treaty-based final BEPS outcomes…
I was recently asked to analyze the often quoted figure of $150 billion lost by the U.S. Treasury to foreign non-tax compliance by U.S. taxpayers. My transcribed remarks are below. Also, see…
The path from bank secrecy to automatic exchange of information and beyond
Giant steps towards international transparency: The 2008 and 2014 Milestones
In 2015 OECD released its Update on Voluntary…
