There is no doubt that 7 June 2017 is a day that will be a milestone in the history of international tax law. Signature of the Multilateral Convention to Implement Tax Treaty Related Measures to…
A world of tax without disputes is an illusion. It is just as much an illusion as a world without tax. Tax and disputes come together inseparably. Disputes is not something to be ashamed of – I say…
As widely reported by the news media, a major corporate tax reform has been under discussion in the United States, which may cause spillover effects on taxpayers engaged in cross-border transactions…
As a member of the Organization for Economic Co-operation and Development (“OECD”) Mexico[1] has been actively involved in the design and development of the Base Erosion and Profit Shifting (BEPS)…
Cornerstone of modern tax systems is the somehow forgotten axiom that taxpayers need to consent to the taxes imposed by governments. This may sound peculiar in an era where political correctness…
Consider this. Formula One World Championship Limited UK (Formula One) entered into a Race Promotion Contract (RPC) with Jaypee Sports International Limited (Jaypee), an Indian entity, under which…
On 24 April 2017 the Indian Supreme Court held that Formula One World Championship Ltd, the holder of the commercial rights to the Formula One Grand Prix, had a permanent establishment in India at…
In March 2017, the OECD and the IMF published a report on tax uncertainty (Report) confirming that such uncertainty exists and impacts on business and investment. Similar was the outcome of an…
Foreign enterprises for the purpose of Indian Income Tax (IT) Act are enterprises that are incorporated outside India or that do not have their place of effective management in India (as per new…
I was recently asked to analyze the often quoted figure of $150 billion lost by the U.S. Treasury to foreign non-tax compliance by U.S. taxpayers. My transcribed remarks are below. Also, see…
