US Tax Court resolves Eaton’s transfer pricing dispute – By Elisa Kaminsky, BaseFirma, Miami
The US Tax Court issued a written opinion on October 28 regarding Eaton’s transfer pricing court case. The resolution of […]
Poland’s new cooperative compliance program for large taxpayers – By Dr. Monika Laskowska, Center of Tax Analyses and Studies, Warsaw School of Economics
On 6 November, Poland’s President signed a law implementing a new cooperative compliance program in Poland for large corporate taxpayers
The United Nations’ effort to shape global transfer pricing policy – By George L. Salis, Principal Economist & Tax Policy Advisor, Vertex, Inc., King of Prussia, Pennsylvania
The 19th Session of the United Nations Committee of Experts on International Cooperation in Tax Matters was held October 15-18
OECD releases 2500+ pages of public comments to its pillar one “unified approach” for taxing multinationals – By Julie Martin, MNE Tax
The OECD on November 15 published more than 300 comment letters that respond to its request for feedback on the
China simplifies procedure for claiming tax treaty benefits – By Agnes Lo, Lingnan University, Hong Kong & Raymond Wong, Associate Dean, City University of Hong Kong
China’s State Taxation Administration on 14 October published “Administrative Measures for Non-resident Taxpayers Claiming Tax Treaty Benefits” [Announcement (2019) No.
OECD seeks feedback on the effectiveness of 13 countries’ cross-border tax dispute resolution processes – By Julie Martin, MNE Tax
The OECD today requested input from taxpayers to assist in an assessment of the timeliness and efficiency of the cross-border
Colombia issues new guidance on the taxation of permanent establishments and branches – By Carlos Subero, Senior Consultant, BaseFirma Colombia
On October 29, the Colombian government published Decree 1973, providing detailed rules on the attribution of income to a permanent
The GloBE puzzle: a debate way beyond use of financial accounts – By Dr. Leopoldo Parada, University of Leeds School of Law
A few days before closing the public consultation on the OECD Secretariat’s pillar 1 unified approach, the OECD released a
WTO: Pushing exports: India must rethink trade policy
By: Mukesh Butani | Published: November 18, 2019 4:34:32 AM While the trade policy mandarins of the GoI will look for solutions, the
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Tax Treaty Overrides: A Qualified Defense of U.S. Practice – Reuven S. Avi-Yonah
The ability of some countries to unilaterally change, or “override,” their tax treaties through domestic legislation has frequently been identified
Tax Treaty Overrides: A Qualified Defense of U.S. Practice – Reuven S. Avi-Yonah Read Post »
An analysis of the South African general anti-avoidance rules: Exploring Australian judicial experience – N Bauer and DP Schutte
The decisions of recent Australian case law relating to the general anti-avoidance regime was cause for concern among the Australian
GAAR AS TAX TREATY OVERRIDE – SLOVAK PERSPECTIVE
Download GAAR AS TAX TREATY OVERRIDE – SLOVAK PERSPECTIVE
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