Mutual agreement procedure (MAP) pursuant to article 25 of the OECD and UN Model treaties imposes obligations on tax administrations. Inadequacies in the performance of these obligations has been the…
Beginning 1 January 2020, Switzerland will significantly reshape its corporate taxation in an effort to comply with international tax standards while remaining one of the most attractive…
I am delighted to inform you that the June-July 2019 double issue of Intertax has been published. It includes the editorial by Stef van Weeghel, Digitalization in a Broader Tax Perspective; double-…
Taxation of the digital economy has become a war in the post-BEPS world. As with any war, there are more or less clear rivals and there will be of course winners and losers. It goes without saying…
The quest to align the international tax order with the challenges posed by the digital economy has so far mostly focused on solving issues involving incorporated structures. What is somehow escaping…
BEPS Action Plan 6 observes that corporations are misusing Double Taxation Avoidance Agreement (DTAA) provisions by indulging in treaty shopping. A typical example of treaty abuse that BEPS Action…
This is the first article of a short series that explores the international taxation of income attributable to Autonomous Artificial Intelligence (AAI). The series is based on an article written by…
Corresponding adjustments and the MAP process
When the price charged for goods or services sold between related parties is not in accordance with the arm’s length principle, Article 9(1) of the OECD…
I wrote in my last blog that despite its impact, corporate tax avoidance is one of the lesser debated issues in India.
This is what I wrote: “Multinational tax avoidance has almost never made it to…
There has been much brouhaha about equalization levies in the context of the digital economy. One of the hotly debated issues is whether such levies are covered by tax treaties at all. In this post,…
