The Anti-Tax Avoidance Directive (ATAD) is the European answer to the phenomenon of BEPS: Base Erosion and Profit Shifting. Characteristically for tax avoidance by Base Erosion and Profit Shifting,…
As previously reported on this Blog the EU Anti-Tax Avoidance Package was presented on 28th January 2016. The package included:
- Recommendation on Tax Treaties
- Amended Directive…
Volume 44 (2016), Issue 8/9 contains:
EDITORIAL:
Andreas OESTREICHER, 'To See or Not to See: That Is Not the Question'
ARTICLES:
Georg KOFLER, 'Some Reflections on the ‘Saving Clause’'
Abstract:…
On September 14th, 2016, the Brazilian Federal Revenue Service (“RFB”) published the Normative Instruction RFB No. 1,658/2016, which included legal entities incorporated as holding companies in…
An important question in the context of the recovery of fiscal state aid, is how the amount of the tax advantage to be recovered should be calculated.
Recently, the Dutch legislator released a draft…
This has been an interesting session and for those who were not there, I am sure that the essence is reported elsewhere in the international tax press. The deliberations lead me to the following…
Random thoughts on presumptions on accuracy
It is a fact that most in-house tax professionals know very little about their group’s financial systems. E.g. very few know whether their companies…
Introduction. I have been actively supporting an EU based corporate income tax to reflect the single internal market rather than a fragmented framework with 28 competing tax laws. I’ve done so since…
Tax practitioner’s in the northern hemisphere taking their summer holidays may well have included the OECD discussion draft of 5 July 2016 on the attribution of profits to permanent establishments as…
Much has been written – and probably even more has been said – about the different consequences of the Brexit vote. This is hardly a surprise: the decision is a first in the history of the European…
