According to EU law the prevailing divergences between the national tax systems shall not be corrected by unilateral measures that grant fiscal advantages to firms, which are affected by the…
So what were the other discussions at the UN from 19 to 23 October this year? One of the main topics is the continuing work on a withholding tax on technical services. The reason for developing…
An open door for emerging economies or the beginning of the end in international tax co-ordination
In an article published earlier this year,[1. Teijeiro, Opening the Pandora’s Box in the…
Both Starbucks and Fiat represent, if one listened closely to the live press release broadcast, an first salvo by the EU Commission to establish that it has the authority, under a State Aid premise,…
Today the European Commission released its first set of decisions on corporate tax rulings, which it has investigated for over a year. Starbucks Manufacturing EMEA and Fiat Finance and Trade were the…
It is the annual Session of the UN Committee of Experts on International Cooperation in Tax Matters. This Ad Hoc subsidiary body of the Economic and Social Council of the UN (ECOSOC) is responsible…
As from the first BEPS proposals with respect to intangibles, it has been considered that the Arm’s Length Standard (“ALS”) is “slowly but surely being relegated to the back seat” of the OECD…
The scope of the present article will be narrow. The aim is to point out a misinterpretation of the Cadbury ruling, which might have caused a flawed theory of the compatibility of certain CFC regimes…
China has risen as a key global economic development engine and player over the past three decades. An evidentiary lynchpin derived from such mighty economic advances is China’s gradually escalating…
Today at 2 pm the OECD announced the final BEPS action plan on a live webstreamed news conference.
Though this was very high level, it did not seem as though the final versions of the 15 action plans…
