In the 1980s, a new dimension to profit shifting was introduced in the United States through the establishment of Onshore Offshore Banks. New legislation (called the International Banking Facility (…
It is widely accepted that the United States of America is one of the most litigious countries on earth. As of 2010, US residents spent about 2.2% of their GDP (approximately 310 Billion Dollars)…
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…
We are happy to inform you that the latest issue of the journal is now available and includes, among others, the following contributions:
An editorial, Taxes and Regulation, by Alice Pirlot and…
The COVID-19 pandemic has led to unprecedented times for the world. Many countries, including India, most of Western Europe and some states of the US have now imposed mandatory lockdowns, in addition…
Measures to prevent the spread of coronavirus have impacted on every aspect of life. While the degree of enforced isolation and immobility varies from country to country, the basic elements remain…
The purpose of this short contribution is to shed some light on the discussion regarding an Uber drivers’ qualification – whether they should be considered employees or independent contractors. If…
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…
The decisions of European Court of Justice (CJEU) in the Vodafone and Tesco cases[1] were eagerly awaited by many interested in EU tax law. It was expected that the CJEU would answer the question…
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…
