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.…
Tag: INTERNATIONAL TAX LAW
The relationship between treaties and domestic anti-abuse provisions
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…