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…
Our 14-page comments and recommendations of 14 tax professionals and academics from 11 countries raise additional issues and concerns, and propose additional recommendations to undertake a detailed…
May linking rules related to hybrid financial instruments be incompatible with the EU Fundamental freedoms? And with Article 24 (4) OECD MC? What about treaty override?
It is no secret that hybrid…
On 14 November 2019, AG Kokott released her opinion in Dong Yang Electronics (Case C-547/18), referred to the Court of Justice of European Union (CJEU) by the Regional Administrative Court of Wroclaw…
In June 2017, the European Commission published its proposal on transparency rules for tax planning by intermediaries and certain taxpayers (the Commission proposal). The Commission proposal was…
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…
Equality is one of the core values of modern democratic societies. It is no accident that equality featured in opening preamble to the United States Declaration of Independence in 1776 and the first…
The digital economy is faced with major challenges for the international tax system since the traditional tax rules seem to be insufficiently well designed to govern new ways of conducting businesses…
