IRS Operational Update: Reorganization and Risk-Based Approach
The IRS new Large Business and International (LB&I) risk approach has been implemented in the form of “campaigns”, focusing on…
The decision of the CJEU in Republic of Austria v Federal Republic of Germany (Case C-648/15) on 12 September 2017 is a landmark decision in tax treaty dispute resolution. Han Verhagen raised…
In March I blogged about the first OECD draft guidance on the allocation of profits to commissionaire and other PE’s. Looking at the June OECD draft, further ideas have come up as to why the…
On 12 September 2017, the CJEU confirmed that it has jurisdiction over a dispute between Austria and Germany regarding the interpretation of a double tax convention entered into between the two…
As widely reported, the signing ceremony of the Multilateral Convention to implement tax treaty related measures to prevent Base Erosion and Profit Shifting ("MLI") took place on 7 June 2017, in…
Limited Liability Companies have become one of the most common forms of business organisation in the United States. Their main attraction is a combination of limited liability for LLC members and…
“The judge who always likes the results he reaches is a bad judge,” Justice Antonin Scalia had famously said. A recent ruling delivered by the Bengaluru Bench of the Indian Income Tax Tribunal in ABB…
The objective of the EU Merger Directive (“MD”) is to remove tax obstacles to cross-border restructuring operations while safeguarding the financial interests of the Member States.[1] In aligning…
More and more soccer players hit the newspapers because they are not just creative in the soccer stadiums but also in dealing with their tax returns. Recently we have seen the press reporting on…
This contribution lays down a general plan for what the EU should do in order to attain a harmonized set of norms regulating the allocation of taxing rights among Member States and in the relation…
