Volume 44 (2016) Issue 2 contains:
EDITORIAL
Dennis WEBER, 'The New Common Minimum Anti-Abuse Rule in the EU Parent-Subsidiary Directive: Background, Impact, Applicability, Purpose and Effect'…
What do these two things have in common? Dr. Andrew P. Morriss, Dean & Anthony G. Buzbee Dean's Endowed Chair, Texas A&M School of Law explains
In 1998, seven US heavy-duty diesel engine (…
Introduction
On 28 January 2016, the proposal for a council directive laying down rules against tax avoidance practices that directly affect the functioning of the internal market (the so-called ATA-…
Lessons to LatAm from recent developments of one of the oldest tax treaty networks in the region
The final outcome of Action 6, BEPS, posses the query of adopting the principal purpose test (PPT)…
Volume 25 (2016) Issue 1 contains:
EDITORIAL
Pierre Moscovici, 'Tough Measures Needed to Reform Tax on Corporate Profits'
ARTICLES
Silvia Velarde ARAMAYO, 'A Common GAAR to Protect the Harmonized…
After a decade, the Treasury Department issued a new U.S. Model Income Tax Convention (the “2016 Model”), which is the baseline text the Treasury Department uses when it negotiates tax treaties (last…
When the EU Anti Tax Avoidance Package was launched by the European Commission, a Study on Structures of Aggressive Tax Planning and Indicators was released simultaneously as Taxation papers –…
Model tax treaties do matter. The OECD and UN Models constitute precedent books with standard clauses that contracting states can follow or adapt to suit their particular circumstances. The US Model…
(“Every in-house tax department should have their own IT/Financial systems capacity” – JHM, TP Minds London, 2015.)
The unexpected benefit from country by reporting (“CbyC”) reporting is that tax…
MNC profit shifting has received major attention over the past few years. Total earnings stockpiled overseas are now reported to be in excess of $2 trillion. One of the authors published a technical…
