Volume 25 (2016) Issue 1 contains:
EDITORIAL
Pierre Moscovici, 'Tough Measures Needed to Reform Tax on Corporate Profits'
ARTICLES
Silvia Velarde ARAMAYO, 'A Common GAAR to Protect the Harmonized…
After a decade, the Treasury Department issued a new U.S. Model Income Tax Convention (the “2016 Model”), which is the baseline text the Treasury Department uses when it negotiates tax treaties (last…
When the EU Anti Tax Avoidance Package was launched by the European Commission, a Study on Structures of Aggressive Tax Planning and Indicators was released simultaneously as Taxation papers –…
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…
(“Every in-house tax department should have their own IT/Financial systems capacity” – JHM, TP Minds London, 2015.)
The unexpected benefit from country by reporting (“CbyC”) reporting is that tax…
MNC profit shifting has received major attention over the past few years. Total earnings stockpiled overseas are now reported to be in excess of $2 trillion. One of the authors published a technical…
(about the switch-over clause in the ATA Directive)
In order to combat BEPS, the European Commission is proposing to start taxing low taxed non-EU income. That sounds reasonable, but the consequence…
On 28 January 2016, the European Commission issued its proposal for a Council Directive dealing with tax avoidance practices within the EU – the so-called Anti-BEPS Directive. The context of the…
I. Introduction
Shall international tax planning decrease after the implementation of BEPS? The reply is "depends" by virtue of the subject’s exposure to several variables.
Obviously, one should…
The IRS issued Notice 16-08 announcing that it will extend timelines or modify four elements of FATCA -
(1) modify the date for submitting to the IRS the preexisting account certifications required…
