The DTT’s signed by the LATAM countries generally follow the rule included both in the OECD and UN Tax-Convention Models. Article 24 Section 1 states that “nationals of a contracting state shall not…
Whoever thinks that a resident company's income is protected from taxation in countries where it has no PE, is in for a rude awakening; it is not. The allowance for CFC rules in the OECD Model…
There are a lot of opinions on multinationals and their tax practices. One conventional perception is that multinationals have a general tax advantage over their domestic competitors as their…
Following my latest post on the Court of Justice’s decision in Commission v UK (C-172/13, ECLI:EU:C:2015:50), I want to turn in this comment on the related issue of currency losses, which was…
This month’s Haydon Perryman and William Byrnes FATCA Update post starts with a tip-of-the-hat to my FATCA and CRS research colleague Haydon Perryman who has just moved to UBS Investment Bank where…
This contribution is aimed at surveying the interaction and reciprocal influence between the OECD-G20 BEPS Action Plan (the BEPS Plan), on one hand, and contemporary tax developments occurred in the…
Tax treaty rules to resolve the dual residence of persons other than individuals have been consistent since the 1963 OECD draft convention. Such dual residence in resolved by Article 4(3) of the OECD…
The ministers signed a Supplementary Agreement (SA) amending the French-German Double Taxation Convention. The SA simplifies the taxation for pensioners by attributing the exclusive taxing right for…
The claim for the so-called “single taxation principle”, in spite of its doubtful general acceptance, seems to have been acknowledged by the OECD, which has moved from a position whereby countries…
Reform Path Forward for China’s Tax Law Reform
The observation on the current fiscal and tax system helps China to improve and execute a profound tax system to realize goals proposed in The…
