Introduction
One of the most controversial topics of transfer pricing, in today's multinational world, is the pricing of intercompany financial transactions. The 2017 OECD transfer pricing guidelines…
The Existing Framework: Nexus and Profit Attribution Rules
Under the current Double Taxation Avoidance Agreement (DTAA) framework, business profits are in principle taxable in the State of residence…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:
Marie Lamensch, Adoption of the E-Commerce VAT Package: The Road…
Being familiar with the Spanish tax environment, readers will know that Spain does not withhold taxes on interest paid to EU residents. This domestic exemption has been in force for several decades,…
I am delighted to see that my post on value creation has stimulated discussion on the fundamental thinking about international taxation. See the posts of my friends and colleagues Werner Haslehner…
The well-known expression “butterfly effect” comes from chaos theory, and it refers to the idea that a butterfly could flap its wings in Brazil and, through ripple effect, set off a tornado in Texas…
For many years, I have been advocating a drastic change in the distribution approach for taxing rights in international taxation. The focus of my criticism has been Article 7 of the OECD and UN Model…
Intertax dedicates this special issue to digital taxation, aiming to contribute to the ongoing debate on the topic. The reader will find herein the entire range of existing positions, discussed…
Economic development has been historically associated with the fulfilment of two major conditions: a) Peace and b) low taxation. Peace was the necessary component for prosperity from the point of…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:
Nathalie Wittock, Sales Promotion Techniques and VAT
Sales promotion…
