A. Where are we? A worldwide and LATAM picture
A current worldwide picture of unilateral initiatives developed on the direct taxation of the digitalized economy includes at least the following paths…
On June 9, 2019 the G20 finance ministers endorsed the program of work that was issued by the OECD’s Inclusive Framework on BEPS on May 31, 2019 in relation to tax challenges arising from the…
Introduction
The taxation of cryptocurrencies has managed to attract strong interest even among the general Finnish population. A key reason has been the perceived unfairness of crypto taxation,…
This is a short series of blogs on transfer pricing documentation: what I have seen over the years, how it does (not) align with OECD documentation requirements, and thoughts on possible improvements…
In a double take two-to-one decision because of a withdrawn decision due to the death of a judge, a Ninth Circuit panel in Altera reversed a unanimous en banc decision of the Tax Court that the…
Mutual agreement procedure (MAP) pursuant to article 25 of the OECD and UN Model treaties imposes obligations on tax administrations. Inadequacies in the performance of these obligations has been the…
Beginning 1 January 2020, Switzerland will significantly reshape its corporate taxation in an effort to comply with international tax standards while remaining one of the most attractive…
I am delighted to inform you that the June-July 2019 double issue of Intertax has been published. It includes the editorial by Stef van Weeghel, Digitalization in a Broader Tax Perspective; double-…
Taxation of the digital economy has become a war in the post-BEPS world. As with any war, there are more or less clear rivals and there will be of course winners and losers. It goes without saying…
The quest to align the international tax order with the challenges posed by the digital economy has so far mostly focused on solving issues involving incorporated structures. What is somehow escaping…
