BEPS Action 14 vs Treaty Obligations and State Aids
Maisto e Associati The OECD Public Discussion Draft on BEPS Action 14 (released on 18 December 2014) covers extensively dispute resolution mechanisms and ways to make them more effective. The subject...
View ArticleA Mysterious Study in the Code of Conduct Report 1999 and a Rumoured French...
Dorean Global Tax Policy BV Let’s go back a few weeks, to March 18, 2015. The EU Commission announces its much heralded Tax Transparency package. The package contains a surprise element: the link to...
View ArticleIRS Issues New Competent Authority and Advance Pricing Agreement Procedures
Texas A&M University Law On August 12, 2015 the IRS released two final revenue procedures impacting the U.S. transfer pricing regime. Revenue Procedure 2015-40 concerns the protocols and...
View ArticleMultilateral Tax Treaty: if we build it, will they come?
Temple Tax Chambers; King’s College London In many respects a multilateral tax treaty represents an utopian view of international tax law: a wide consensus among nation states to submit themselves to a...
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