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…
1. The Tendency
We live in a time where the media, politicians, NGOs and activists increasingly are preoccupied with international tax matters. A simultaneous preoccupation is observed among the OECD…
Change is the only constant! As businesses find new ways to operate, tax authorities are finding new ways to tax. All is fair in the world of taxes!
The tax world has been brimming with, news and…
On 6 June 2016, the European Commission finally released its decision in the McDonald’s State Aid case. After the clarifications recently provided on the Commission’s position concerning transfer…
1. The international context: OECD giant steps towards international transparency
Last year OECD released its Update on Voluntary Disclosure Programs: A pathway to tax compliance, a renewed edition…
William Byrnes with Haydon Perryman
This month we turn our attention to the recently revised 2016 W-8BEN-E form which has 30 parts over eight pages that can be catalogued into four sections. The IRS…
Volume 44, Issue 5 contains:
ARTICLES:
Roland ISMER, Sophia PIOTROWSKI, 'A BIT Too Much: Or How Best to Resolve Tax Treaty Disputes?'
Abstract: State to state disputes under tax treaties are…
I want to talk about TP documentation. If what I say seems a little crazy, then at least of part of it is to be deliberately provocative. I attended a wonderful TP conference in London in March with…
I recently participated in a seminar on tax & innovation in Naples, my home town where I stay often to arrange personal issues, which has a sparkling start-up community, in an increasingly…
In highly dramatic fashion the French tax authorities and IT specialists raided Google's headquarters and McDonalds. I don't own Google stock. I'm not in favor of Google's near monopoly on search (…
