This has been an interesting session and for those who were not there, I am sure that the essence is reported elsewhere in the international tax press. The deliberations lead me to the following…
Random thoughts on presumptions on accuracy
It is a fact that most in-house tax professionals know very little about their group’s financial systems. E.g. very few know whether their companies…
Introduction. I have been actively supporting an EU based corporate income tax to reflect the single internal market rather than a fragmented framework with 28 competing tax laws. I’ve done so since…
Tax practitioner’s in the northern hemisphere taking their summer holidays may well have included the OECD discussion draft of 5 July 2016 on the attribution of profits to permanent establishments as…
Much has been written – and probably even more has been said – about the different consequences of the Brexit vote. This is hardly a surprise: the decision is a first in the history of the European…
A considerable increase of transfer pricing disputes could be observed in Italy over the last decade.
Notwithstanding the rising trend of proceedings activated by the Tax Authorities and further…
If the UK leaves the EU, this would have immediate consequences for direct taxation.[1] We saw in the first post that the EU fundamental freedoms, EU provisions on State aid and EU directives and…
On 24 August 2016, the US Treasury Department issued a White Paper on “The European Commission’s Recent State Aid Investigations of Transfer Pricing Rules” (the “White Paper”), denouncing the…
The post-BEPS international tax scenario is in transition to a much more inter-nation equitable system, where the national tax base will be much better protected against erosion and profit-shifting…
A thought-provoking and insightful series of papers on taxpayer rights have just been published in the latest edition of The Tax Lawyer,[1] published by the American Bar Association Section of…
