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Jakob Bundgaard  (CORIT advisory)
How Should EU Member States Implement the Recommendations Following from the OECD BEPS Project? – A Comment to the Recently Published Discussion Draft on Action 3
April 13, 2015

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…

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Guillermo O. Teijeiro  (Bomchil)
BEPS Action 3: Public Discussion Draft on Strengthening CFC Rules: A Legal Critique to the Possible Implementation of a Full-income CFC System
April 09, 2015

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…

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Jonathan Schwarz  (Temple Tax Chambers; King’s College London)
Employees of International Organisations: Pensions Taxation
April 08, 2015

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.…

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Catalina Hoyos  (Godoy & Hoyos Abogados)
Will Colombia be able to get rid of the Financial Transactions Tax (FTT)?
April 07, 2015

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…

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Tianlong Hu  (Law School and International Monetary Institute, Renmin University of China)
The Hitched Stride
April 01, 2015

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.…

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Johann Müller  (International tax professional)
How Competing Agendas hurt Business in BEPS
March 26, 2015

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…

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Tiago Cassiano Neves  (Garrigues)
What BEPS Tax Project is (really) all about?
March 24, 2015

“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…

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William Byrnes  (Texas A&M University Law)
FATCA Update of March 2015
March 19, 2015

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…

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Manfred Naumann  (Transfer Pricing Specialist)
International Tax Competition and Patent Boxes
March 18, 2015

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…

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Guillermo O. Teijeiro  (Bomchil)
The OECD-G20 BEPS Project and the Challenges ahead
March 16, 2015

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…

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