Earlier this month, the author of this blog was at the IFA UK branch meeting where experts assembled to discuss certain interpretational aspects concerning the BEPS Multilateral Instrument (BEPS MLI…
Background
Action 6 of BEPS introduced the principal purpose test (PPT) as one of the Minimum Standards to be implemented by the countries/jurisdictions taking part in the BEPS Inclusive Framework…
In the introductory blog to this series, I talked about how many local files do not look like the OECD documentation requirements and that it is probably the consequence of pre-existing files being (…
The Income Tax Appellate Tribunal (hereinafter referred to as the “Tribunal”), Mumbai delivered a landmark judgment in the case involving two parties namely, Elsevier Information Systems Gmbh and Dy…
On 11 July 2019, the event “Global Transfer Pricing Standard and Brazilian Approach: The Way Forward” took place in Brasilia, in which the Organization for Economic Cooperation and Development (OECD…
This is the second article of a short series that explores the international taxation of income attributable to Autonomous Artificial Intelligence (AAI). The series is based on an article written by…
The judgments of the European Court of Justice (ECJ) on the withholding tax exemption provided by the Interest and Royalties Directive (available here – the ‘IRD judgment’) and the Parent-Subsidiary…
Brazilian Transfer Pricing Rules have been in force since 1996. When introduced, the intent of the legislator was clearly the prevention of tax evasion through manipulation of prices, though setting…
I have received several requests this July 4th holiday in the U.S. about my initial thoughts on the EU Commission's 56-page published (public version from earlier this week) State Aid preliminary…
Commissioner of Taxation v Resource Capital Fund IV LP [2019] FCAFC 51 addressed a number of fundamental international tax issues. The case concerned a gain from the sale of shares in an Australian…
