Introduction
While tax legislation is subject to continuous changes, tax treaties are an interesting tool whereby Contracting States offer investors some degree of legal certainty, especially where…
Harmonisation of the efforts to discourage tax avoidance in the EU
Recently, besides the objective of maintaining a balanced allocation1 (a reflection of the principle of territoriality), the…
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…
On June 24 the British people voted in favour of the UK leaving the EU. The vote itself does not automatically imply the withdrawal from the EU: indeed, such withdrawal shall take place pursuant to…
“I know there's a proverb which that says 'To err is human,' but a human error is nothing to what a computer can do if it tries.” - Agatha Christie, Hallowe'en Party
The now
Have you ever wondered…
Corporate Social Responsibility (“CSR”) has become one of the top priorities on the Agenda of almost all supranational bodies (OECD, EU, UN) and many jurisdictions. Due to the overall lack of…
On June 27, 2016 the EU Commission published the long awaited Starbucks State Aid decision (see here). The EU Commission’s decision challenges the outcome of the Advanced Pricing Agreement (APA)…
Is tax avoidance a bad thing? The international tax community seems recently to adopt an almost unanimous position: Yes, it is supposedly a very bad thing, as it not only reduces public revenue, but…
Probably without noticing it, Colombia did not take into account that signing the recent DTT with France would allow some treaty-covered taxpayers to claim Most-Favoured-Nation (MFN) protection.
Some…
“Improper and plainly undermines legal certainty and the rule of law.” This is how four U.S. senators – including the Chairman and Ranking Member of the U.S. Senate Finance Committee – recently…
