Treasury recently released its 2015 Transfer Pricing Advance Pricing Agreements Report to Congress, the seventeenth report since the initial 1999 report. Each year, the Treasury APA Report describes…
A critical appraisal of the EU Switch Over Rule and the Indian Equalization Levy
At present, it is unavoidable to recognize that the international tax scenario is in transition to a much more inter-…
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…
That day in November 2012
It was 5 November 2012 when G20 Finance Ministers asked for a report on the root-causes of Base Erosion and Profit Shifting, by their next meeting in February 2013.…
Volume 44 (2016) Issue 3 contains:
ARTICLES
José Manuel Calderón CARRERO, Alberto Quintas SEARA, 'The Concept of ‘Aggressive Tax Planning’ Launched by the OECD and the EU Commission in the BEPS Era:…
India’s 2016 Budget is proof that the Government is not only aware of major tax developments taking place globally, but is also sincere in bringing the country’s municipal tax system into line with…
Volume 44 (2016) Issue 2 contains:
EDITORIAL
Dennis WEBER, 'The New Common Minimum Anti-Abuse Rule in the EU Parent-Subsidiary Directive: Background, Impact, Applicability, Purpose and Effect'…
What do these two things have in common? Dr. Andrew P. Morriss, Dean & Anthony G. Buzbee Dean's Endowed Chair, Texas A&M School of Law explains
In 1998, seven US heavy-duty diesel engine (…
Introduction
On 28 January 2016, the proposal for a council directive laying down rules against tax avoidance practices that directly affect the functioning of the internal market (the so-called ATA-…
Lessons to LatAm from recent developments of one of the oldest tax treaty networks in the region
The final outcome of Action 6, BEPS, posses the query of adopting the principal purpose test (PPT)…
