Introduction
The new European Commission that is taking shape shall inherit quite a heavy file of initiatives to pursue in the next five years. Certainly, this is the case in the area of taxation.…
The OECD Work Programme published in May of this year under the OECD/G20 Inclusive Framework on BEPS aims to achieve a consensus solution to the problems of taxing the digital economy.
The OECD Work…
Globally, countries are making a concerted effort to rein in the direct tax challenges posed by the digital economy. Some of this work is directly inspired by the recommendations set out by the OECD…
In this blog, I shall examine the policy and characteristics underlying the split-rate system of taxing corporate profits/income. I shall also discuss the issue whether the Indian Dividend…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:
Rita de la Feria, The New VAT General Reverse-Charge Mechanism
In…
DNB (Dutch Central Bank) issued on July 2 2019 a Guideline entitled “Good practices tax integrity risks at clients of banks” (Good practices fiscale integriteitsrisico’s bij cliënten van banken). The…
I am happy to inform you that the latest issue of the journal is now available and is mainly dedicated to International Tax Arbitration, where ground-breaking and complementary perspectives on Tax…
Two of my recent articles have examined the Australian decision in Commissioner of Taxation v Resource Capital Fund IV LP [2019] FCAFC 51. The articles examine the central question on the source of…
Purpose of the blog
The purpose of this blog is to address whether the transactional profit split method (TPSM) applies to centralized business models operated by multinational enterprises (MNEs).…
Since the news of the Brazilian request to accede to the OECD broke out, much has been speculated about the future of the Brazilian TP approach. Brazil is historically one of the major economies to…