A global silver alert for fair and efficient tax systems is active already for a couple of years.
The heated debate sparked all over the world has engaged national governments, NGOs, international…
Publication of text of The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention) by the OECD on 24 November 2016 is one of the…
Volume 25 (2016) issue 4 contains:
EDITORIAL:
Han KOGELS, 'Base Erosion and Profit Shifting and Value Added Tax in the Digital Economy'
ARTICLES:
Pieter van OS, 'Interest Limitation under the Adopted…
There are many things in life that we take for certainties, which are not, e.g. that it was the Scots that invented whiskey, the French champagne, or the Italians pizza. All not necessarily true.…
In a decision that offers the much-needed certainty in the tax treatment of income arising from the cross-border transfer of rights in intangibles used by Indian subsidiaries of multinational…
To refresh memories, several months ago I posted part 1 of this study on Kluwer's International Tax Blog: Application of TNMM to Starbucks Roasting Operation: Seeking Comparables Through…
The path from bank secrecy to automatic exchange of information and beyond
Giant steps towards international transparency: The 2008 and 2014 Milestones
In 2015 OECD released its Update on Voluntary…
Brazil is known for its unique transfer pricing legislation. While in most countries the use of comparables is central for the application of the transfer pricing methods, the Brazilian system has…
The transition from bilateralism to multilateralism in regard of international law-making seems to be a relentless work in progress. Nobody contests that multilateralism would be – legally speaking…
The OECD has today published details of the peer review and monitoring process of the Mutual Agreement Procedure (MAP) under Action 14 of the BEPS Action Plan.
The framework includes the terms of…
