Arm's Length Principle

Climate change and the use of natural resources present us all with a major challenge. We all have our part in it and we can all contribute to ensure that we do not live at the expense of future…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Han Kogels, A Changing World Making the Road to Carbon Neutrality Even More…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Stefan Greil, Michael Overesch, Anna Rohlfing-Bastian, Ulrich Schreiber &…

When the UK introduced its diverted profits tax, I was telephoned by a lawyer at the US Treasury. He wanted to know whether the “just and reasonable” apportionment of profits, in certain…

In my last blog, I looked at the immediate impact of Covid 19 Lockdowns on key elements of double tax treaties – residence, permanent establishment and employment income. Many tax administrations…

To refresh memories, several months ago I posted part 1 of this study on Kluwer's International Tax Blog: Application of TNMM to Starbucks Roasting Operation: Seeking Comparables Through…

A considerable increase of transfer pricing disputes could be observed in Italy over the last decade. Notwithstanding the rising trend of proceedings activated by the Tax Authorities and further…

Harmonisation of the efforts to discourage tax avoidance in the EU Recently, besides the objective of maintaining a balanced allocation1 (a reflection of the principle of territoriality), the…

“Improper and plainly undermines legal certainty and the rule of law.”  This is how four U.S. senators – including the Chairman and Ranking Member of the U.S. Senate Finance Committee – recently…