We have all become familiar with the expression in the PPT set out in article 7(1) of the MLI and article 29(9) of the 2017 OECD Model where “obtaining that benefit was one of the principal purposes…
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…
In a globalized economy, financial crimes --including tax crimes-- threaten the strategic, political and economic interest of developed and developing countries as well, and undermine confidence in…
Co-authored with Hans van den Hurk, Maastricht University, QuanteraGlobal Tax Policy. Note that the authors write in their personal capacity.
Policymakers are changing the international tax system to…
