United Nations

Tax treaty negotiators in 100 countries will be tied up over the next few months with the challenge to evaluate their positions on the BEPS Multilateral Convention (BEPS Convention) with a view to…

A recent ruling in GE Money Financial Services Pvt. Ltd. v. DCIT, the Income Tax Appellate Tribunal (ITAT) has further contributed to the uncertainties in Transfer Pricing in India. The ruling is a…

Brazil is known for its unique transfer pricing legislation. While in most countries the use of comparables is central for the application of the transfer pricing methods, the Brazilian system has…

The OECD has today published details of the peer review and monitoring process of the Mutual Agreement Procedure (MAP) under Action 14 of the BEPS Action Plan. The framework includes the terms of…

The attribution of profits to a permanent establishment is already a complex issue with at least three separate regimes in the tax treaty context- the OECD Authorised Approach under the 2010 OECD…

Corporate Social Responsibility (“CSR”) has become one of the top priorities on the Agenda of almost all supranational bodies (OECD, EU, UN) and many jurisdictions. Due to the overall lack of…

The OECD BEPS project was kicked off by the observation that the interaction of domestic tax systems sometimes leads to an overlap, resulting in double taxation as well as gaps, which result in an…

Model tax treaties do matter. The OECD and UN Models constitute precedent books with standard clauses that contracting states can follow or adapt to suit their particular circumstances. The US Model…

Interest and penalty regimes place a high premium on correctly identifying the existence of a permanent establishment in the territory of a state. The failure to do so often means that there is no…