How much would Starbucks pay me for coffee?
Independent International Tax Professional Introduction It has been a few weeks now since the Commission has made public its decisions in the FIAT and Starbucks cases. I understand that the...
View ArticleDarwin & Corporate Taxation – Has the Evolution of the Economy Killed the...
CORIT advisory Written by Associate Professor, PhD, Michael Tell, Department of Law, Copenhagen Business School and Technical Advisor, CORIT Advisory. Darwin’s theory of evolution states that complex...
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Fifty shades of fair exit taxation of corporations
Mircea and Partners Law Firm The raison d’être of corporate taxation relates to the aim of achieving an impartial treatment of different legal forms in order to safeguard a level playing field for...
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Will the US Impose Double US Tax Rates on EU Companies from Countries that...
Texas A&M University Law On January 15, 2016, in a joint (bi-partisan) letter of Senate Finance Committee Republicans and Democrats to US Treasury, one that will certainly be of interest to our...
View ArticleThe Commission Proposal for an Anti-BEPS Directive: Some Preliminary Comments
Luxembourg University On 28 January 2016, the European Commission issued its proposal for a Council Directive dealing with tax avoidance practices within the EU – the so-called Anti-BEPS Directive. The...
View ArticleEU BEPS / Taxing Low-Taxed Non-EU Income: Think Twice…
Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff (about the switch-over clause in the ATA Directive) In order to combat BEPS, the European Commission is proposing...
View ArticleThe Interest Limitation Rule of the Proposed EU Anti-Tax Avoidance Directive:...
Loyens & Loeff Introduction On 28 January 2016, the proposal for a council directive laying down rules against tax avoidance practices that directly affect the functioning of the internal market...
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