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Guillermo O. Teijeiro  (Bomchil)
The Panama Papers Affair and the challenges ahead: AEOI and Beneficial ownership
April 25, 2016

Massive leaks of information on offshore activity like the Panama Papers illustrate the need for an enhanced global tax cooperation with an improved and deeper interjurisdictional information sharing…

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Jonathan Schwarz  (Temple Tax Chambers; King’s College London)
Pension funds and tax treaties: "Four legs good, two legs bad" or "Four legs good, two legs better"?
April 22, 2016

George Orwell's parable, Animal Farm, offers insights on political and governmental institutions that bear revisiting from time to time. BEPS Action 6 with the broad title “Prevent treaty abuse” has…

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Johann Müller  (International tax professional)
TP by numbers (1/3)
April 20, 2016

This is the first part of a series about numbers in transfer pricing. In this edition, I look at sticking the TP five methods on a typical profit and loss account (hereafter “P&L”). I find it…

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Raffaele Russo  (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Chiomenti)
Panama Papers: Four (personal) reflections - beyond the media storm
April 18, 2016

The dust has not settled yet and there is probably much more to come from this and future leaks. Investigations have started, international cooperation will be key and hopefully those that have not…

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William Byrnes  (Texas A&M University Law)
U.S. APA Transfer Pricing and LB&I ReStructure / Audit Process Update
April 11, 2016

Treasury recently released its 2015 Transfer Pricing Advance Pricing Agreements Report to Congress, the seventeenth report since the initial 1999 report.  Each year, the Treasury APA Report describes…

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Guillermo O. Teijeiro  (Bomchil)
Detecting clouds before the Post-BEPS storm becomes uncontrolled
March 30, 2016

A critical appraisal of the EU Switch Over Rule and the Indian Equalization Levy At present, it is unavoidable to recognize that the international tax scenario is in transition to a much more inter-…

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Jonathan Schwarz  (Temple Tax Chambers; King’s College London)
BEPS Transfer Pricing Implementation: consensus-based framework or unilateral measures which lead to global tax chaos marked by massive re-emergence of double taxation?
March 23, 2016

The OECD BEPS project was kicked off by the observation that the interaction of domestic tax systems sometimes leads to an overlap, resulting in double taxation as well as gaps, which result in an…

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Raffaele Russo  (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Chiomenti)
3 BEPS Years, a (Very) Personal Perspective
March 14, 2016

That day in November 2012 It was 5 November 2012 when G20 Finance Ministers asked for a report on the root-causes of Base Erosion and Profit Shifting, by their next meeting in February 2013.…

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Fred de Hosson  (General Editor Intertax and Of Counsel at Baker McKenzie)
The Contents of Intertax, Volume 44, Issue 3, 2016
March 12, 2016

Volume 44 (2016) Issue 3 contains: ARTICLES José Manuel Calderón CARRERO, Alberto Quintas SEARA, 'The Concept of ‘Aggressive Tax Planning’ Launched by the OECD and the EU Commission in the BEPS Era:…

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Shilpa Goel  (Tax Lawyer)
India Catching Up On International Tax Reform
March 11, 2016

India’s 2016 Budget is proof that the Government is not only aware of major tax developments taking place globally, but is also sincere in bringing the country’s municipal tax system into line with…

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