In 2015, people around the globe celebrated the 800th anniversary of the Magna Carta Libertatum, considered to be the first constitutional-like document that established restrictions on a sovereign’s…
The Indian Ministry of Finance released last month draft guidance on applying the “place of effective management” (POEM) test to determine tax residence of companies. The guidance came almost eight…
On January 15, 2016, in a joint (bi-partisan) letter of Senate Finance Committee Republicans and Democrats to US Treasury, one that will certainly be of interest to our friends at Wolters Kluwer (a…
Interest and penalty regimes place a high premium on correctly identifying the existence of a permanent establishment in the territory of a state. The failure to do so often means that there is no…
Volume 44 (2016) Issue 1 contains:
EDITORIAL
Ana Paulo DOURADO, 'May You Live In Interesting Times'
Abstract: In the current global tax good governance context, exchange of information is one…
In his last State of the Union speech on January 13, 2016 Obama put it quite clear: “The United States of America is the most powerful nation on Earth. Period. It's not even close.”
With this…
Howdy from Prof. Haydon Perryman and I of Texas A&M University. This month we undertake a 2015 review of FATCA’s GIIN registrations relative to 2014. We also include a chart at the end of this…
"Your net worth to the world is usually determined by what remains after your bad habits are subtracted from your good ones." Benjamin Franklin
Organisations generally, when starting a business in …
A Latin American Perspective
Until very recently tax risk management concepts were quite stable. The over-riding principle in this area was and still is that tax risk is best managed by the…
The Spanish National Court has recently ruled (case no. 182/2012) that a Spanish affiliate of Dell that sold Dell computers in Spain under a commissionaire agreement with Dell Ireland constituted a…
