A critical appraisal of the EU Switch Over Rule and the Indian Equalization Levy
At present, it is unavoidable to recognize that the international tax scenario is in transition to a much more inter…
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…
On January 15, 2016, in a joint (bi-partisan) letter of Senate Finance Committee Republicans and Democrats to US Treasury, one that will certainly be of interest to our friends at Wolters Kluwer (a…
So what were the other discussions at the UN from 19 to 23 October this year? One of the main topics is the continuing work on a withholding tax on technical services. The reason for developing…
The case brings about the opportunity to fill a gap in the Norwegian tax law. In order to determine the fiscal residence of a corporation, the current formula stipulated by art. 2(2) Tax Act uses the…
The DTT’s signed by the LATAM countries generally follow the rule included both in the OECD and UN Tax-Convention Models. Article 24 Section 1 states that “nationals of a contracting state shall not…
The taxation of MNEs is widely debated. This is even more so with respect to MNE’s tax planning arrangements. Increasingly, however, it seems that politicians and the media are not paying enough…
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…
