It is well known that case law from the European Court of Justice (ECJ) imposes limitations on the application of anti-avoidance rules by Member States. Accordingly, it is of vital importance that…
In July 2013, the OECD published its Action Plan on Base Erosion and Profit Shifting, aimed at ensuring the coherence of corporate income taxation at the international level. Action 3 of the Plan…
When internationally mobile workers retire, they look to Art 18 of the OECD Model tax treaty to determine their tax treatment if they are private sector workers. Government workers look to Art 19.…
One of the most polemical tax measures in Colombia’s recent taxation history has undoubtedly been the introduction of the Financial Transactions Tax (FTT). Loved by the public administration but…
In my previous post, I discussed the budget law related reform updates in China. This post continues such discussion by reviewing issues of China’s tax administration and transfer payment systems.…
I ”grew up” believing that publications of the OECD are the bibles of taxation. They are scientific master pieces, tell you what to do and, like other holy books, are often open for multiple…
“You never want a serious crisis to go to waste”, Rahm Emanuel, Chicago Mayor (and former Obama White House chief-of-staff)
Fundamental reforms are always controversial and the G20/OECD hard-pressed…
GIIN Lists Analysis: June 2014 through March 2015
In the words of my English colleague Haydon Perryman, March was a “bit of a damp squib”. Financial institution FATCA registrations have slowed to a…
Two years ago, the OECD’s BEPS project started with the goal that Multinational Enterprises pay their fair share of taxes. There was some hope that unfair tax competition, especially in the form of…
The OECD-G20 BEPS Project's goal is ciclopeous: Making the global tax environment fairer than ever by closing loopholes and adopting rules of international law which would be domesticated…
