Posted by: Michael Devereux on March 27, 2019
The recent OECD consultation, notionally on the tax challenges brought by the digitalisation of the economy, has resulted in over 230 responses, from ACCA to Zalando. If it were just about new rules for a handful of large digital companies, that would be surprising. But it is not. The changes afoot go right to the […]
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Posted by: Alice Pirlot on December 18, 2018
Over the past years, a broad range of tax measures have faced criticism due to their alleged incompatibility with the law of the World Trade Organization (WTO). In 2016, when the United States considered moving from traditional corporate income taxes to destination-based taxes, some tax academics argued that the proposal was contrary to WTO […]
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Posted by: Paul Morton on December 3, 2018
The international tax system is too complicated. Is it even right to call this dishevelled, mountainous conglomeration a “system”? The combination of complex and rapidly expanding domestic law, the ever-increasing complexity of international business exacerbated by digitalisation, and the growing number of domestic tax disputes is leading to ever greater uncertainty for business. Heaped over […]
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Posted by: Michael Devereux on October 23, 2018
The American bank robber Willie Sutton is best remembered for an answer (which he claimed never to have given) to the question “why do you rob banks?”. The answer was “that’s where the money is”. I’d like to suggest that proposals – from HM Treasury, the EU, and others – for a digital services tax […]
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Posted by: Rita De la Feria on May 2, 2018
Last month the UK Parliament’s Treasury Select Committee announced the launch of three new enquiries on different aspects of tax enforcement. Whilst the enquiries will address tax avoidance concerns, the biggest emphasis is on tax fraud and enforcement. This is very welcome. Whilst tax policy tends to get the headlines tax enforcement is fundamental for […]
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Posted by: Richard Collier on March 26, 2018
THE ARM’S LENGTH PRINCIPLE (“ALP”) – IS IT A PRINCIPLE AND IS IT ARM’S LENGTH? What is the ALP? The definitive statement of the ALP is set out in Article 9 (1) of the OECD Model Double Tax Treaty. Broadly, this tells us that where “conditions are made or imposed” between associated enterprises in their […]
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Posted by: John Vella on February 21, 2018
There is widespread political agreement that tax reform is needed to address the problems that digitalisation poses to business taxation, as recently evidenced by the EU Commission’s Communication and HM Treasury’s Position Paper on the issue. The OECD is expected to publish an interim report on digitalisation in April 2018. We will comment on these […]
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Posted by: Alice Pirlot on January 26, 2018
Taxing pollution across borders: an innovative proposal? Around one year ago, Lakshmi Mittal – the chairman of ArcelorMittal – published an opinion piece in the Financial Times, in which he called for the adoption of a “carbon border tax” in Europe. Around the same time, the Climate Leadership Council – a US-based conservative organization […]
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Posted by: Eddy Tam on January 18, 2018
The Autumn Budget 2017 announced a reduction in stamp duty for residential properties under £500,000 purchased by first-time buyers. But how much will first-time buyers actually benefit? Existing research suggests only 60% of the gain from this reduction will go to the buyer. Some first-time buyers should benefit more than others – for example, those […]
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Posted by: Scott Dyreng on December 13, 2017
The House and the Senate have passed tax reform bills in the U.S. The process has reminded me of how my 8-year-old son washes the dinner dishes: fast and without attention to detail. If you’ve ever had an 8-year-old, (or been an 8-year-old) you know what I mean. The bills are designed to fix America’s […]
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