In line with BEPS Action 12, the Brazilian President enacted, on July 21, 2015, the Provisional Measure ("MP") no. 685, creating the obligation for taxpayers to disclose aggressive tax plannings.…
Please contact us to assist in our research Prof. William Byrnes & Haydon Perryman
In 2011, HMRC forecast that it would receive "billions" from the Swiss Disclosure Facility. In 2012, HMRC…
Attacking Profit Shifting by Prof. Jeffery Kadet (Abstract) In recent years the financial press has turned increasing attention to MNCs that shift income to low taxed jurisdictions overseas in order…
In our previous blog we were discussing issues of non-discrimination on the basis of Nationality (article 24.1 MOCDE). Today, it is relevant to point out the fact that the idea of non-discrimination…
FFI GIIN List FATCA Monthly Update
The IRS released the fourteenth FATCA GIIN list of foreign financial institutions (FFIs) that have registered with the IRS through its FATCA portal. The IRS…
Dr. Andrew P. Morriss is Dean & Anthony G. Buzbee Dean’s Endowed Chairholder, Texas A&M University School of Law; Drew Estes is a JD/MBA Candidate, Class of 2016, University of Alabama.…
What is going on in the corporate tax world? In 2013 I predicted BEPS would be a success, at least based on the press release to be issued by OECD and G20 on January 1, 2016. I have always been a…
The 2010 Green Paper from the EU Commission led to significant amendments to the EU Auditor regulation (see REGULATION (EU) No 537/2014 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 April 2014…
On 17 June 2015, the Commission adopted a plan to relaunch the 3CTB (Common Consolidated Corporate Tax Base), a common system for calculating the tax base of businesses operating in the EU. Except,…
Part 1 of the Report to G20 Development Working group (DWG) on the impact of BEPS in Low Income countries (LICs), dated July 2014, listed in its Section 6: Other High priority BEPS Issues for…
