General
On February 9, 2017, the Court of Justice of the European Union (‘CJEU’) rendered its decision in the X v Staatssecretaris van Financiën (‘X’). The case concerned the possibility of…
In a 207 page opinion the Tax Court ruled March 23, 2017 that the IRS’s adjustment with respect to Amazon.Inc's transfer pricing buy-in payment for an intragroup cost sharing agreement (CSA) is…
In quantum physics, nothing is certain, particles are not to be found at one point but within waves of probabilities and connected particles can mirror each other faster than the speed of light…
If there was ever a need to demonstrate the need to improve international tax dispute resolution mechanisms, it was as a speaker at the TP Minds conference earlier this month. In the course of our…
Introduction and EU law applicable
On 8 March 2017 the Court of Justice of the European Union (hereafter “CJ”) delivered its decision in the Case C-448/15, Wereldhave, dealing with the interpretation…
Lower energy cost is a major factor for U.S. manufacturers … to be able to offer on par production costs to China, and 10 percent to 20 percent lower costs than European manufacture.
I’ve been remiss…
On 16 February 2017 the Public Consultation on the proposed introduction of rules at EU level to disincentivize promotion of aggressive tax planning schemes was closed. The rules under consideration…
The Italian Supreme Court issued a landmark case (n. 27113 December 2016) setting out the principles to be taken into account when analyzing whether a company can be deemed the “beneficial owner” for…
In March, 2015, in wrote in this same pages: “The BEPS Project is subject to internal (inherent) risks (tight schedule, quality of outcomes, jurisdictional overlapping) as well as external risks (…
Tax treaty negotiators in 100 countries will be tied up over the next few months with the challenge to evaluate their positions on the BEPS Multilateral Convention (BEPS Convention) with a view to…
