International Tax Bytes: 7 October 2022

ATL-Editor 10 October 2022

ITB is a weekly PodCast by Steve Towers. It covers all major global tax events for any given week.

07 October 2022: This week’s highlights

Latest developments on Pillars One & Two
Progress report on administration and tax certainty aspects of Amount A in Pillar One
Report on tax incentives and GloBE rules
Belgium announces that it will proceed with implementation of GloBE rules, even without Hungary’s agreement
Interesting international tax cases and rulings
UK case on unilateral foreign tax credits
Spanish ruling on application of GAAR to chain of transactions
Continuation of detailed review of GloBE model rules
Today: paras. (f) to (h) in Art. 6.2.1, on Constituent Entities joining and leaving an MNEWhat 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 Group

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Categories: FP News

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S.Africa: Summary of the Davis Tax Committee’s BEPS Sub-committee General Report released December 2014

Summary of the Davis Tax Committee’s BEPSBEPS stands for "Base Erosion and Profit Shifting". BEPS refers to tax avoidance strategies used by multinational enterprises (MNEs) to exploit gaps and mismatches in the international tax system. By shifting profits from high-tax jurisdictions to low- or no-tax locations, MNEs reduce their overall tax burden, even if little to no economic activity occurs in the low-tax jurisdictions. These practices erode... More Sub-committee General Report released December 2014 by Peter Dachs of ENS Introduction This note provides a summary of

ATL-Editor 26 February 2015

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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

Cook Islands: FATCA’s impact – this paper applies to many other offshore centres

April/May 2015[1] Impact of FATCA on Cook Islands Entities[2] TABLE OF CONTENTS Background The key differences between FATCA and IGA Models 1 and 2

ATL-Editor 27 April 2015

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AFRICA: Sub-Saharan Africa and international arbitration – how does that work?

COMMENT Tax arbitration via new double tax treaties is on the increase. Hence, knowledge of international arbitration is important. Take a look at the following

ATL-Editor 29 August 2014

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Byrnes’ Comments on the OECD’s “Unified Approach” to Allocation of Profits of Digital Business

BEPSBEPS stands for "Base Erosion and Profit Shifting". BEPS refers to tax avoidance strategies used by multinational enterprises (MNEs) to exploit gaps and mismatches in the international tax system. By shifting profits from high-tax jurisdictions to low- or no-tax locations, MNEs reduce their overall tax burden, even if little to no economic activity occurs in the low-tax jurisdictions. These practices erode... More, DIGITAL SERVICES TAX, DIGITALIZATION, 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, PERMANENT ESTABLISHMENTS, TRANSFER PRICINGTransfer pricing is a fundamental concept in international taxation that defines the pricing methods and rules applied to transactions between related entities within a multinational enterprise (MNE). In the context of tax regulations, it governs how prices for goods, services, or intangibles (such as intellectual property) are set when these items are exchanged between different branches, subsidiaries, or affiliates of... More William Byrnes (Texas A&M University Law)/October 10, 2019 In my International TaxationFOR MORE INSIGHT ON INTERNATIONAL TAXATION, PLEASE READ THIS ARTICLE: Introduction to International Taxation: Key Concepts & Guidelines International Taxation encompasses the framework of laws, principles, and treaties that govern the tax obligations of individuals and entities engaged in economic activities that span multiple jurisdictions. This field addresses how income, profits, and gains are taxed when operations or investments extend... More class tomorrow (October 10th) we are going to discuss the OECD’s

ATL-Editor 10 October 2019

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