OECD Archives - Page 2 of 3 - Academy of Tax Law

Understanding Double Tax Treaties: A Comprehensive Guide

*For clarity, the term Double Tax TreatyA Double Taxation AgreementA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and... More (DTAA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and... More), also known as a Double TaxationDouble Taxation occurs when the same income or financial transaction is taxed twice, typically in different jurisdictions. It can arise in two primary contexts: economic double taxation, where the same income is taxed twice in the hands of different taxpayers, and juridical double taxation, where the same taxpayer is taxed on the same income in more than one country. Double... More Treaty (or a Tax TreatyA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs have become essential tools for promoting trade, investment, and... More), is an international

ATL-Editor 28 August 2024

Mutual Agreement Procedures (MAP): Key Guidelines

Mutual Agreement Procedures (MAP) are key mechanisms that ensure fair tax treatment in international transactions. They help resolve conflicts between…

Dr Daniel N Erasmus 28 August 2024

The Second Session of the Ad Hoc Committee on the UN Tax Convention

The Second Session of the Ad Hoc Committee on the UN Tax Convention, held from July 29 to August 16, 2024, at the UN Headquarters in New York, was a s…

Dr Daniel N Erasmus 17 August 2024

The OECD’s Transfer Pricing Framework for Mineral Pricing

Transfer pricing in the mineral sector is a complex yet crucial aspect of international tax compliance. The OECD has developed a comprehensive framewo…

Dr Daniel N Erasmus 13 August 2024

Italian Supreme Court Ruling on Transfer Pricing: Inclusion of Loss-Making Entities in Comparability Analyses

The Italian Supreme Court's 2024 ruling mandates including loss-making entities in transfer pricing comparability analysis, aligning with OECD guideli…

Dr Daniel N Erasmus 12 August 2024

X BV v Netherlands (Staatssecretaris van Financiën Case)

The X BV v Staatssecretaris van Financiën case revolves around a key issue in corporate tax: the denial of interest deductions for intra-group loans …

Dr Daniel N Erasmus 15 March 2024

Canada (Her Majesty the Queen) v. Cameco Corporation

The Federal Court of Appeal's ruling in the case between Her Majesty The Queen and Cameco Corporation centers on the application of Canada's transfer …

Dr Daniel N Erasmus 29 June 2020

Transfer Pricing Guidance on Financial Transactions

INCLUSIVE FRAMEWORK ON BEPSBEPS stands for “Base Erosion and Profit Shifting”. BEPS refers to tax avoidanceTax avoidance refers to the practice of legally structuring financial activities to minimise tax liability, reducing the amount of tax owed without violating laws. Unlike tax evasion, which is illegal and involves concealing income or misreporting, tax avoidance operates within the framework of the law. Multinational enterprises (MNEs) and individuals often engage in tax planning strategies that reduce tax liabilities... More strategies used by multinational enterprisesWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More (MNEsWhat are Multinational Enterprises (MNEs)? Multinational Enterprises, commonly referred to as MNEs, are corporations that operate in multiple countries through various subsidiaries, branches, or affiliates. These entities maintain a central management structure while leveraging diverse resources, labour markets, and customer bases across borders. The fundamental aspect that distinguishes MNEs from other corporate forms is their cross-border activity, which can include... More) to exploit gaps and

ATL-Editor 18 February 2020

OECD tax proposal gathers pace, but many unanswered questions

Published by Lexology Article by: Macfarlanes LLP – Rhiannon Kinghall Were Last week (9 December) the OECDThe Organisation for Economic Co-operation and DevelopmentThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD's core mission is to promote policies that improve... More (OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD's core mission is to promote policies that improve... More) is an international

ATL-Editor 6 January 2020

The OECD opens a public consultation for its proposals on digitalisation of the economy under Pillar Two (rules for tackling the erosion of tax bases and the transfer of profits)

Published by Lexology Article by: Osborne Clarke – Daniel Rioperez and Ana Malagon On November 8, 2019, the OECDThe Organisation for Economic Co-operation and DevelopmentThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD's core mission is to promote policies that improve... More (OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop solutions to common economic challenges. The OECD's core mission is to promote policies that improve... More) is an international

ATL-Editor 6 January 2020