“A camel is an animal designed by a committee” – Anonymous
In launching the BEPS programme in 2013, the OECD warned that replacement of the current consensus-based framework by unilateral measures,…
Publication of text of The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention) by the OECD on 24 November 2016 is one of the…
The OECD has today published details of the peer review and monitoring process of the Mutual Agreement Procedure (MAP) under Action 14 of the BEPS Action Plan.
The framework includes the terms of…
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…
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…
The attribution of profits to a permanent establishment is already a complex issue with at least three separate regimes in the tax treaty context- the OECD Authorised Approach under the 2010 OECD…
When UK voters went to the polls on 23 June 2016 and voted by a slim majority to leave the European Union, few of them had in mind the impact on taxation. Future generations are unlikely to view it…
George Orwell's parable, Animal Farm, offers insights on political and governmental institutions that bear revisiting from time to time. BEPS Action 6 with the broad title “Prevent treaty abuse” has…
The OECD BEPS project was kicked off by the observation that the interaction of domestic tax systems sometimes leads to an overlap, resulting in double taxation as well as gaps, which result in an…
Model tax treaties do matter. The OECD and UN Models constitute precedent books with standard clauses that contracting states can follow or adapt to suit their particular circumstances. The US Model…
