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William Byrnes  (Texas A&M University Law)
2015's FATCA GIIN Analysis
January 20, 2016

Howdy from Prof. Haydon Perryman and I of Texas A&M University.  This month we undertake a 2015 review of FATCA’s GIIN registrations relative to 2014.  We also include a chart at the end of this…

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Mariette Cruywagen  (Partner/Director, Infinite Tax)
Africa - to outsource tax compliance
January 18, 2016

"Your net worth to the world is usually determined by what remains after your bad habits are subtracted from your good ones." Benjamin Franklin Organisations generally, when starting a business in …

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Guillermo O. Teijeiro  (Bomchil)
Tax Risk Management in BEPS Times: A Trap for the Unwary?
January 04, 2016

A Latin American Perspective Until very recently tax risk management concepts were quite stable. The over-riding principle in this area was and still is that tax risk is best managed by the…

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Jonathan Schwarz  (Temple Tax Chambers; King’s College London)
Agency Permanent Establishments: Commissionaires in the frame
December 16, 2015

The Spanish National Court has recently ruled (case no. 182/2012) that a Spanish affiliate of Dell that sold Dell computers in Spain under a commissionaire agreement with Dell Ireland constituted a…

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Werner Haslehner  (Luxembourg University)
Double (Non)Taxation, Transfer Pricing and State Aid
December 11, 2015

Since the press releases confirming negative State Aid decisions in the Starbucks and Fiat tax ruling cases late October, the EU tax law community is still eagerly awaiting the publication of the…

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William Byrnes  (Texas A&M University Law)
The Netherlands Appeals the Starbucks Decision
December 09, 2015

Starbucks Manufacturing BV (SMBV), based in the Netherlands, is the only coffee roasting company in the Starbucks group in Europe. It sells and distributes roasted coffee and coffee-related products…

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Guillermo O. Teijeiro  (Bomchil)
BEPS Project at half way - Entering the implementation stage
November 30, 2015

Taxation is undoubtedly the unrivaled field where public interest needs and individual rights most evidently confront to each other. Until the second part of the last decade, the principle of reserve…

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Emanuela Matei  (Mircea and Partners Law Firm)
Fifty shades of fair exit taxation of corporations
November 27, 2015

The raison d’être of corporate taxation relates to the aim of achieving an impartial treatment of different legal forms in order to safeguard a level playing field for conducting business. In the EU…

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William Byrnes  (Texas A&M University Law)
FATCA November GIIN and IDES Updates
November 25, 2015

This month, Haydon Perryman and I review the change over the past year, and the immediate previous three months, for FATCA financial institution registrations.  The November 1, 2015 GIIN list…

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Jakob Bundgaard  (CORIT advisory)
Darwin & Corporate Taxation – Has the Evolution of the Economy Killed the Basis for Corporate Taxation?
November 23, 2015

Written by Associate Professor, PhD, Michael Tell, Department of Law, Copenhagen Business School and Technical Advisor, CORIT Advisory. Darwin’s theory of evolution states that complex creatures…

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