Google’s international corporate structure and operating model has featured significantly in the political and legal debate about the taxation of multinational companies, particularly in the…
The Spanish National Court has recently ruled (case no. 182/2012) that a Spanish affiliate of Dell that sold Dell computers in Spain under a commissionaire agreement with Dell Ireland constituted a…
Article 7(1) of the OECD model treaty is perhaps the most important rule regulating the international taxation of business. It sets out the fundamental basis on which businesses are taxed, that is,…
