FP News

Colombia issues new guidance on the taxation of permanent establishments and branches – By Carlos Subero, Senior Consultant, BaseFirma Colombia

On October 29, the Colombian government published Decree 1973, providing detailed rules on the attribution of income to a permanent establishment or branch of a multinational corporation. According to the new guidance, foreign companies and entities must pay income taxIncome Tax is a direct levy imposed by governments on the income generated by individuals, corporations, […]

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The GloBE puzzle: a debate way beyond use of financial accounts – By Dr. Leopoldo Parada, University of Leeds School of Law

A few days before closing the public consultation on the OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy experiences, and develop

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WTO: Pushing exports: India must rethink trade policy

By: Mukesh Butani | Published: November 18, 2019 4:34:32 AM While the trade policy mandarins of the GoI will look for solutions, the message is clear—time is up for dole-outs for promoting exports, and competitiveness of exports must be driven by quality. On October 31, a panel constituted under the World Trade Organisation’s (WTO’s) dispute settlement mechanism issued

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Tax Treaty Overrides: A Qualified Defense of U.S. Practice – Reuven S. Avi-Yonah

The ability of some countries to unilaterally change, or “override,” their tax treaties through domestic legislation has frequently been identified as a serious threat to the bilateral tax treatyA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that

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An analysis of the South African general anti-avoidance rules: Exploring Australian judicial experience – N Bauer and DP Schutte

The decisions of recent Australian case law relating to the general anti-avoidance regime was cause for concern among the Australian tax community, as the Assistant Treasurer proclaimed that the Australian Government will protect the integrity of the Australian tax system by making amendments to the general anti-avoidance regime as a direct response to the loss

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GAAR AS TAX TREATY OVERRIDE – SLOVAK PERSPECTIVE

Download GAAR AS TAX TREATYA Double Taxation Agreement (DTA), also known as a Double Taxation Treaty (or a Tax Treaty), is an international tax treaty between two or more countries that aims to prevent individuals or businesses from being taxed twice on the same income. With globalisation and the increase in cross-border economic activities, DTAs

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Corporate tax planning developments in South Africa

ENSafrica A company is defined in the Income TaxIncome Tax is a direct levy imposed by governments on the income generated by individuals, corporations, and other entities within a specific jurisdiction. It serves as a major source of revenue for governments and funds various public expenditures, such as infrastructure projects, healthcare, education, national security, and

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OECD and EU updates on TP related issues

OECD consults on “Pillar Two” global minimum tax proposal November 8, 2019 The OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade, and development on a global scale. Founded in 1961, the OECD provides a forum for governments to collaborate, share policy

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