On 14 August 2014 the Philippines Court of Tax Appeals (“CTA”) decided case no. 1041 regarding Goodyear. However, the underlying issue was already decided in March 2013 by the same court in case no.…
If time allows, I try to contribute to the OECD discussions submitting comments to their draft papers. Last November and December 2014, the OECD came out with several drafts for discussion (…
General Introduction
From 1 July 2014, U.S. withholding agents have imposed, with very limited exceptions, the new Internal Revenue Code (IRC) Chapter 4 withholding (a.k.a. FATCA) of 30 percent…
I would like to use eight to ten posts to discuss the status quo of China’s fiscal and taxation law system and proposals for reform thereto. This first post will discuss the most recent development…
Uncertainty
“When nothing is sure, everything is possible” – Margaret Drabble
So often when people find out that I travel to Africa, the first thing I am asked is whether I ever feel unsafe. My…
2015 is full of new legislations to be applied by Brazilian companies, and investors should definitely wait for more changes in the tax arena, as the Brazilian Federal Government has had problems of…
The current global tax landscape changes fast and it is not difficult to find a topic for a blog. Do I start with the G20 angle for raising revenue, with the intra-country tax competition, with the…
An issue of topical interest for tax administrations in the heat of the BEPS Plan, examining the existence of a PE does not seem to be on the agenda of Brazilian authorities. In a ruling from June,…
The OECD Joint Working Group on Business Restructurings is, in many respects, the precursor to the OECD BEPS project. Unresolved Business Restructuring issues, particularly in relation to permanent…
It is well known that the world’s economies have turned into a global economy during the last decades. Moreover, it is nowadays common knowledge – also outside the professional tax community – that…
