“When the map and the territory don’t agree, always believe the territory” Gause and Weinberg – describing Swedish Army Training
Easier said than done
Tax risk management in Africa reminds me of how…
The taxation of MNEs is widely debated. This is even more so with respect to MNE’s tax planning arrangements. Increasingly, however, it seems that politicians and the media are not paying enough…
On 11 February 2015 a US District Court found that the US Internal Revenue Service disclosed false tax return information to the Japanese National Tax Administration contrary to the Japan-US tax…
The OECD Public Discussion Draft on BEPS Action 14 (released on 18 December 2014) covers extensively dispute resolution mechanisms and ways to make them more effective. The subject has grown in…
On 14 August 2014 the Philippines Court of Tax Appeals (“CTA”) decided case no. 1041 regarding Goodyear. However, the underlying issue was already decided in March 2013 by the same court in case no.…
If time allows, I try to contribute to the OECD discussions submitting comments to their draft papers. Last November and December 2014, the OECD came out with several drafts for discussion (…
General Introduction
From 1 July 2014, U.S. withholding agents have imposed, with very limited exceptions, the new Internal Revenue Code (IRC) Chapter 4 withholding (a.k.a. FATCA) of 30 percent…
I would like to use eight to ten posts to discuss the status quo of China’s fiscal and taxation law system and proposals for reform thereto. This first post will discuss the most recent development…
Uncertainty
“When nothing is sure, everything is possible” – Margaret Drabble
So often when people find out that I travel to Africa, the first thing I am asked is whether I ever feel unsafe. My…
2015 is full of new legislations to be applied by Brazilian companies, and investors should definitely wait for more changes in the tax arena, as the Brazilian Federal Government has had problems of…
