Allocation issues: Transfer pricing and tax avoidance: just and reasonable solutions?
Article by Jonathan Schwarz (first published on KluwerTaxBlog) When the UK introduced its diverted profits tax, I was telephoned by a lawyer at the US Treasury.…
Article by Jonathan Schwarz (first published on KluwerTaxBlog) When the UK introduced its diverted profits tax, I was telephoned by a lawyer at the US Treasury.…
By: Mukesh Butani (BMR Legal Advocates) We are pleased to mail you an Opinion piece as weekend long-read on the subject. The issue on claim…
Article by: Pawel Mikula, First published on KluwerTaxBlog One function of the law is to regulate human behaviour. An instrument to reach this goal is…
Article by: Korina Yiallourou – First published on KluwerTaxBlog In these unprecedented times of the Coronavirus pandemic, governments all around the world are striving to…
Article by: Jonathan Schwarz, first published on KluwerTaxBlog Following the Supreme Court decision in Fowler v HMRC [2020] UKSC 22, the UK First-tier Tribunal has…
Article by: Edoardo Traversa, first published on KluwerTaxBlog International double taxation should be to European VAT harmonization what tropical temperatures should be to the polar…
Article by A&L Goodbody (First published on Lexology) DAC6 is an EU Directive requiring the mandatory disclosure to tax authorities of certain cross-border arrangements. It…
Article by: Johann Müller – First published on KluwerTaxBlog Denmark accepted all MLI articles dealing with PEs, but what does that actually mean? Reading the…
Article by: Jonathan Schwarz (Temple Tax Chambers; King’s College London) – First published on KluwerTaxBlog In last month’s blog I promised to address the treaty…
By Michael Vorndran, Nord Advisory AS, Oslo, Norway (First published on MNE Tax) On 28 May the Norwegian Supreme Court issued a ruling in a transfer…