A thought-provoking and insightful series of papers on taxpayer rights have just been published in the latest edition of The Tax Lawyer,[1] published by the American Bar Association Section of…
Interest and penalty regimes place a high premium on correctly identifying the existence of a permanent establishment in the territory of a state. The failure to do so often means that there is no…
On august 7, 2015, OECD released its Update on Voluntary Disclosure Programmes: A pathway to tax compliance, a renewed edition of the survey published in 2010, aimed at providing guidance to…
The services permanent establishment concept is perhaps the most noteworthy contribution to tax treaties provided by the UN model. The tax treaty concluded by South Africa and the United States in…
