As from the first BEPS proposals with respect to intangibles, it has been considered that the Arm’s Length Standard (“ALS”) is “slowly but surely being relegated to the back seat” of the OECD…
The scope of the present article will be narrow. The aim is to point out a misinterpretation of the Cadbury ruling, which might have caused a flawed theory of the compatibility of certain CFC regimes…
China has risen as a key global economic development engine and player over the past three decades. An evidentiary lynchpin derived from such mighty economic advances is China’s gradually escalating…
Today at 2 pm the OECD announced the final BEPS action plan on a live webstreamed news conference.
Though this was very high level, it did not seem as though the final versions of the 15 action plans…
As a woman, I naturally think that women are wonderful creatures. We are sociable, charming, caring and (almost) always the radiant center of attention. But unfortunately we are accused of having a…
Everyone concerned with international taxation awaits the publication of the final package of BEPS measures by the OECD on Monday 5 October 2015. While the BEPS programme addresses disparities…
In many European countries, the question of legal personality has relevance for determining the transparent character of a business entity for tax purposes and this assessment is even more complex…
William Byrnes and Haydon Perryman FATCA FFI GIIN List Monthly Update
The IRS released the sixteenth FATCA GIIN list of foreign financial institutions (FFIs) that have registered with the IRS through…
In a globalized economy, financial crimes --including tax crimes-- threaten the strategic, political and economic interest of developed and developing countries as well, and undermine confidence in…
On 18 September 2015 the US Treasury issued Notice 2015-66 which announced that the it intends to amend the regulations under chapter 4 (sections 1471-1474) to extend the period of time that certain…
