The first semester of 2018 has witnessed notable – if not unprecedented – activity in the area of tax policy, in the EU as well as internationally. The wind of change tha we sense in international…
Introduction
One of the advantages multinational groups enjoy over standalone companies is that their members have access to each other’s resources (such as, e.g., funding). In particular, less…
What the UK government wants by way of Brexit outcome seems to change daily, with the government and political parties in Parliament divided among various factions. The only legal certainty about…
On July 13, 2018, India’s Central Board of Direct Taxes (CBDT) issued for stakeholders’ comments a consultation document on framing of tax rules in respect of the concept of “significant economic…
A recent decision of the Spanish Supreme Court, of February 26, 2018, in the civil law jurisdiction, may have an unexpected effect on the composition of the boards of directors of the Spanish…
Introduction
One of the most controversial topics of transfer pricing, in today's multinational world, is the pricing of intercompany financial transactions. The 2017 OECD transfer pricing guidelines…
The Existing Framework: Nexus and Profit Attribution Rules
Under the current Double Taxation Avoidance Agreement (DTAA) framework, business profits are in principle taxable in the State of residence…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:
Marie Lamensch, Adoption of the E-Commerce VAT Package: The Road…
Being familiar with the Spanish tax environment, readers will know that Spain does not withhold taxes on interest paid to EU residents. This domestic exemption has been in force for several decades,…
I am delighted to see that my post on value creation has stimulated discussion on the fundamental thinking about international taxation. See the posts of my friends and colleagues Werner Haslehner…
