Can you give examples where domestic tax rules override the UN and OECD Model Treaties?
In this Q&A session, we explore the interaction between domestic tax rules and the provisions of the UN and OECD Model Tax Treaties. While these treat…
Tag: tax law
A Comparative Analysis of Anti-Avoidance Measures in Cross-Border Transactions
In international tax law, striking the right balance between anti-avoidance measures and cross-border economic freedoms is an ongoing challenge. Europ…
Permanent Establishments and Managing International Tax Risks: Insights from Key Cases
The concept of a Permanent Establishment (PE) is central to international taxation and transfer pricing. When multinational enterprises (MNEs) conduct…
X BV v Staatssecretaris van Financiën (Case C-585/22): Preventing Tax Fraud Through Arm’s Length Scrutiny
This case focuses on whether the Netherlands' national tax law, which restricts the deduction of interest paid on intra-group loans in certain scenari…
F SCS vs LUXEMBOURG: Safeguarding Lawyer-Client Confidentiality in Cross-Border Tax Inquiries
This case focuses on whether the Netherlands' national tax law, which restricts the deduction of interest paid on intra-group loans in certain scenari…
Transfer Pricing and Anti-Abuse Rules: Key Lessons from Recent Judicial Rulings
Transfer pricing and anti-abuse rules have increasingly become focal points for multinationals and tax authorities across the globe. These rules are p…
Expert Transfer Pricing Advocate for Multinational Enterprises
Struggling with complex transfer pricing disputes? As an expert transfer pricing advocate with over 30 years of experience, I specialise in assisting …
Conducting a Transfer Pricing Trial (eBook)
The book offers a detailed walkthrough of the stages of preparing for and conducting a transfer pricing trial. From assembling a legal and expert team…
Apple Loses €13 Billion Tax Battle: Quick Take
The final ruling by the European Court of Justice (ECJ) in the Apple-Ireland tax case is a significant moment in the ongoing efforts to address profit…
Exactera’s 2024 TP Symposium
I am pleased to announce that I will be speaking at the upcoming 2024 TP Symposium in Lausanne, Switzerland, on September 17-18. My presentation will …