I ”grew up” believing that publications of the OECD are the bibles of taxation. They are scientific master pieces, tell you what to do and, like other holy books, are often open for multiple…
“You never want a serious crisis to go to waste”, Rahm Emanuel, Chicago Mayor (and former Obama White House chief-of-staff)
Fundamental reforms are always controversial and the G20/OECD hard-pressed…
GIIN Lists Analysis: June 2014 through March 2015
In the words of my English colleague Haydon Perryman, March was a “bit of a damp squib”. Financial institution FATCA registrations have slowed to a…
Two years ago, the OECD’s BEPS project started with the goal that Multinational Enterprises pay their fair share of taxes. There was some hope that unfair tax competition, especially in the form of…
The OECD-G20 BEPS Project's goal is ciclopeous: Making the global tax environment fairer than ever by closing loopholes and adopting rules of international law which would be domesticated…
Two cases recently discussed by the European Court of Justice provide a welcome opportunity to use this space for a quick review of the status of foreign loss relief under EU law. The first is the…
“When the map and the territory don’t agree, always believe the territory” Gause and Weinberg – describing Swedish Army Training
Easier said than done
Tax risk management in Africa reminds me of how…
The taxation of MNEs is widely debated. This is even more so with respect to MNE’s tax planning arrangements. Increasingly, however, it seems that politicians and the media are not paying enough…
On 11 February 2015 a US District Court found that the US Internal Revenue Service disclosed false tax return information to the Japanese National Tax Administration contrary to the Japan-US tax…
The OECD Public Discussion Draft on BEPS Action 14 (released on 18 December 2014) covers extensively dispute resolution mechanisms and ways to make them more effective. The subject has grown in…
