Revised transfer pricing legislation set out in the Finance Act 2019 (No 45 of 2019), sections 24 to 27, represents a radical shift in the Irish approach to this area of international tax law.…
In the year 2017, the Indian Parliament enforced “The Central Goods and Services Tax Act, 2017” [hereinafter “CGST”]. The purpose of the Act was to make a provision for levy and collection of tax on…
Introduction
In an unexpected move, the Mexican government and legislative introduced a sweeping tax reform for 2020, introducing mostly anti-abuse and anti-base erosion rules (the “Reform”).
In one…
The Change of Scenery
On 1 December 2019, the von der Leyen Commission took over for the coming 5 years, and it is called to deliver on a most challenging mandate.
The European identity is questioned…
Two cases, currently before different courts highlight long-standing questions around the attribution of profits to permanent establishments. Irish and United Kingdom law on the attribution of…
In 2017, Brazil sent a formal request to the Organisation for Economic Co-operation and Development (“OECD”) to become one of its members. It seems that this decision -- made by the economic team of…
We are happy to inform you that the latest issue of the journal is now available. It is a special issue on transfer pricing in the digital economy. It combines academics and practitioners’ analysis…
Our 14-page comments and recommendations of 14 tax professionals and academics from 11 countries raise additional issues and concerns, and propose additional recommendations to undertake a detailed…
May linking rules related to hybrid financial instruments be incompatible with the EU Fundamental freedoms? And with Article 24 (4) OECD MC? What about treaty override?
It is no secret that hybrid…
On 14 November 2019, AG Kokott released her opinion in Dong Yang Electronics (Case C-547/18), referred to the Court of Justice of European Union (CJEU) by the Regional Administrative Court of Wroclaw…
