What does the future hold for the Dutch royalty conduit companies?
Reorganising Dutch royalty conduit structures, due to several new rules and regulations that will enter into force in 2014, seems unavoidable, writes Jos Peters Base erosion and profit shifting — what the BEPS does it mean?
Catherine Schultz says that the Obama Administration is very supportive of the BEPS project, but does not have tax reform as a high priority The OECD report on BEPS concerning the perceived abuse of commissionaire structures
Commissionaire structures are to be brought under the working if the permanent establishment article of tax treaties writes Jos Peters The Netherlands: a favourable jurisdiction for intermediate holding companies
Jos Peters discusses how companies can receive a Dutch tax credit for foreign dividend withholding tax FATCA – business support for a global solution
The Foreign Account Tax Compliance Act presents business with unique challenges and an opportunity to find global solutions to a single country’s broadly-applicable tax legislation, Keith Lawson writes Spain: the challenge to set an effective tax policy Rafael Fuster says that Spain faces significant economic and social challenges as a result of the crisis The impact of Financial Transaction Tax (FTT) on financial stability
Emrah Arbak argues that the FTT fails to address the key factors that contributed to he global financial crisis The mini-One Stop Shop for VAT - the start of something big!
Algirdas Šemeta writes that the strength of the single market, and the ease with which businesses can operate cross-border, are among the key determinants in how quickly the EU will return to economic growth Tax avoidance in Europe
Federico Cincotta asks where should the line be drawn between legitimate financial planning and 'abusive' arrangements? The dangers of the new functional risk analysis
This new analysis can lead to the application of entirely subjective standards and create additional uncertainty for taxpayers, write Andrew W Steigleder, David F Abbott, and Brian W Kittle Why should business be interested in tax and development?
Pascal Saint-Amans says that investors have a clear interest in helping build the capacity of tax administrations in the developing world Tax risk management, corporate governance and the enhanced relationship
Tax administrations are stepping up their enforcement efforts writes Grace Perez-Navarro Base erosion and profit shifting
In the aftermath of the biggest financial crisis of our lifetime, fiscal consolidation has become an inescapable reality as many governments seek to rebuild solid foundations for growth, Masatsugu Asakawa writes OECD launches its Global Forum on VAT
Piet Battiau discusses the increasing importance of VAT as a source of government revenue Transfer pricing and the arm’s length principle
The growth of international commerce has led more and more countries to have an active interest in transfer pricing, Joseph Andrus points out The OECD discussion draft on the definition of permanent establishment
Jacques Sasseville looks at the concept of permanent establishment, which is the keystone of the existing tax treaty rules that govern the allocation of taxing rights over the business profits that foreign enterprises derive from a country OECD work on the resolution of international tax disputes
Marlies de Ruiter and Edward Barret discuss Article 25 (Mutual Agreement Procedure) of the OECD Model, which provides a mechanism for the resolution of international tax disputes Global Forum: real change towards international tax cooperation
In times of growing economic uncertainty, international cooperation in tax matters has become a high priority on governments’ agenda. Monica Bhatia writes about the Global Forum on Transparency and Exchange of Information for Tax Purposes Initiatives in the transfer pricing area
Krister Andersson comments on initiatives in the transfer pricing aspects of intangibles International Tax Archive To link to archive articles click here