The first part of this blog post addressed the incompatibility of the anti-hybrid rule proposed by the OECD to the source state ("primary response"), which restricts the right to deduct the payments…
On August 5, 2015 Grant Thornton (GT) published their annual International Business Report, a global "mid market survey covering more than 10,000 companies in 35 economies”. Unfortunately, their…
With the declared aim of curbing cross-border tax arbitrage practiced with hybrid financial instruments, the OECD recommended, in Action 2 of the BEPS project, the adoption of anti-hybrid rules,…
The services permanent establishment concept is perhaps the most noteworthy contribution to tax treaties provided by the UN model. The tax treaty concluded by South Africa and the United States in…
China has made vast strides in environmental protection in the past decade. The Decision further indicates that “ecological civilization” a key development goal for China. Various schemes are being…
In line with BEPS Action 12, the Brazilian President enacted, on July 21, 2015, the Provisional Measure ("MP") no. 685, creating the obligation for taxpayers to disclose aggressive tax plannings.…
Please contact us to assist in our research Prof. William Byrnes & Haydon Perryman
In 2011, HMRC forecast that it would receive "billions" from the Swiss Disclosure Facility. In 2012, HMRC…
Attacking Profit Shifting by Prof. Jeffery Kadet (Abstract) In recent years the financial press has turned increasing attention to MNCs that shift income to low taxed jurisdictions overseas in order…
In our previous blog we were discussing issues of non-discrimination on the basis of Nationality (article 24.1 MOCDE). Today, it is relevant to point out the fact that the idea of non-discrimination…
FFI GIIN List FATCA Monthly Update
The IRS released the fourteenth FATCA GIIN list of foreign financial institutions (FFIs) that have registered with the IRS through its FATCA portal. The IRS…
