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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Posted by: Michael Devereux on December 5, 2017
On November 29, the Centre for Business Taxation (CBT) convened a conference in London on The Future of the Arm’s Length Principle (ALP) with speakers drawn from business, the OECD and academia. This was also an opportunity to mark the publication of a new book by CBT Associate Fellow Richard Collier and a previous head […]
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Posted by: Richard Collier on November 28, 2017
The aftermath of the Paradise Papers affair continues to fill the airwaves and fuel ongoing discussion on tax, as seen in the Chancellor’s asides in the Budget Speech last Wednesday. Unfortunately, however, the overwhelming bulk of commentary struggles to reflect any serious understanding of the issues raised. The mishmash of stories and comments on the […]
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Posted by: Michael Devereux on November 17, 2017
When Margaret Hodge complained about how little tax Amazon paid in the UK, the tax cognoscenti rather patronisingly pointed out that the existing system does not generally give the right to tax profit to the country in which a sale in made. But since then the US House of Representatives Ways and Means Committee, the […]
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