The Multilateral Convention to Implement Tax treaty Related measures to prevent BEPS (the Multilateral BEPS Convention or MLI) rounded up the implementation of the treaty-based final BEPS…
An analysis from a State Aid perspective.
This contribution focuses on the profit split methodology in light of current EU Commission’s investigations in the area of tax rulings and transfer pricing[…
On 23 May the OECD published a Public Discussion Draft on Implementation Guidance on Hard-to-Value intangibles (HTVIs). Comments are due by 30 June 2017, so hurry.
1. Introduction
All guidance by…
FATCA: GIINs and LEIs
Musings of Professor William Byrnes with the tremendous brain power of Haydon Perryman
Firstly, a loud shout out to Haydon Perryman who crunches the IRS GIIN list into workable…
There is no doubt that 7 June 2017 is a day that will be a milestone in the history of international tax law. Signature of the Multilateral Convention to Implement Tax Treaty Related Measures to…
A world of tax without disputes is an illusion. It is just as much an illusion as a world without tax. Tax and disputes come together inseparably. Disputes is not something to be ashamed of – I say…
As widely reported by the news media, a major corporate tax reform has been under discussion in the United States, which may cause spillover effects on taxpayers engaged in cross-border transactions…
As a member of the Organization for Economic Co-operation and Development (“OECD”) Mexico[1] has been actively involved in the design and development of the Base Erosion and Profit Shifting (BEPS)…
Cornerstone of modern tax systems is the somehow forgotten axiom that taxpayers need to consent to the taxes imposed by governments. This may sound peculiar in an era where political correctness…
Consider this. Formula One World Championship Limited UK (Formula One) entered into a Race Promotion Contract (RPC) with Jaypee Sports International Limited (Jaypee), an Indian entity, under which…
