Google’s international corporate structure and operating model has featured significantly in the political and legal debate about the taxation of multinational companies, particularly in the…
On 22 June 2017, the OECD released for public comment the revised discussion draft on the application of the profit split method, which intends to continue the work developed in the OECD Transfer…
Intermediaries (such as: tax advisors, accountants, banks, and lawyers) who design tax structures are now on the Commission’s radar. She recently proposed extensive transparency rules on the basis of…
The Committee on Economic and Monetary Affairs and the Committee on Civil Liberties, Justice and Home Affairs of the European Parliament recently finalized the amendments to the existing Anti-Money…
On June 7, 2017, India joined more than 65 countries in signing the OECD’s Multilateral Instrument to implement tax treaty-related base erosion and profit shifting (BEPS) recommendations. The…
On 21 June 2017, the European Commission released its Proposal on transparency rules for tax intermediaries. It primarily seeks to address concerns raised by the ECOFIN Council and the European…
The Multilateral Convention to Implement Tax treaty Related measures to prevent BEPS (the Multilateral BEPS Convention or MLI) rounded up the implementation of the treaty-based final BEPS…
An analysis from a State Aid perspective.
This contribution focuses on the profit split methodology in light of current EU Commission’s investigations in the area of tax rulings and transfer pricing[…
On 23 May the OECD published a Public Discussion Draft on Implementation Guidance on Hard-to-Value intangibles (HTVIs). Comments are due by 30 June 2017, so hurry.
1. Introduction
All guidance by…
FATCA: GIINs and LEIs
Musings of Professor William Byrnes with the tremendous brain power of Haydon Perryman
Firstly, a loud shout out to Haydon Perryman who crunches the IRS GIIN list into workable…
