India’s Income Tax Appellate Tribunal, Bangalore on September 28, 2017, handed down a decision in which it noted that the profits of a foreign company based in Saudi Arabia cannot be taxed in India…
Adoption of the EU Council Directive on Tax Dispute Resolution Mechanisms in the European Union on 10 October 2017 is a milestone in international tax dispute resolution. The Directive offers a…
Controlled Foreign Corporation rules are a hot issue in Europe and beyond. Last year, EU countries agreed to have national CFC rules in force by 2019. The Big Four - Germany, France, Italy and Spain…
Despite tremendous efforts from OECD/G20 to keep the domestication of BEPS outcomes as smoothly as possible, the current international tax scenario is a rough, somehow agitated transition aimed at…
IRS Operational Update: Reorganization and Risk-Based Approach
The IRS new Large Business and International (LB&I) risk approach has been implemented in the form of “campaigns”, focusing on…
The decision of the CJEU in Republic of Austria v Federal Republic of Germany (Case C-648/15) on 12 September 2017 is a landmark decision in tax treaty dispute resolution. Han Verhagen raised…
In March I blogged about the first OECD draft guidance on the allocation of profits to commissionaire and other PE’s. Looking at the June OECD draft, further ideas have come up as to why the…
On 12 September 2017, the CJEU confirmed that it has jurisdiction over a dispute between Austria and Germany regarding the interpretation of a double tax convention entered into between the two…
As widely reported, the signing ceremony of the Multilateral Convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting ("MLI") took place on 7 June 2017, in…
Limited Liability Companies have become one of the most common forms of business organisation in the United States. Their main attraction is a combination of limited liability for LLC members and…
