So what do Tax and the Christmas Season have in common?
December 22, 2019
Ten of the most frequently made comments on the OECD’s latest digital tax consultation*
May 9, 2019
How not to harmonize EU anti-tax avoidance rules
February 25, 2019
McDonalds tax takeaways
February 4, 2019
Test your ATAD!
August 8, 2018
Do-it-yourself transfer pricing
June 11, 2018
The unbearable burden of (dis)proving EU tax avoidance
May 6, 2018
Digital taxes – who will feel the pain?
February 21, 2018
Six takeaways from my EU blacklist article
January 20, 2018
A US patent box - should you be concerned?
November 27, 2017
I'm busy working on my blog posts. Watch this space!
Mandatory and binding arbitration as well as enhanced dispute prevention measures must accompany any change to market nexus and profit allocation rules.
Any solution to market allocation of taxing rights should apply equally to losses.
Wait for implementation and full impact of BEPS actions and US tax reform.
Unilateral market taxation measures are a bad thing because they lead to distortions, compliance burdens, and double taxation.
There should be no ring-fencing, but on the other hand targeted rules tackle the ‘real problem’.
Any solution should be profit- rather than revenue-based because of over/double taxation, non-neutrality and administrative burden concerns.
Technology and related business models are rapidly changing so any solution based on ‘snap-shot’ concepts and definitions will not be sustainable.
Mechanical or formulaic solutions are inaccurate and unfair, but on the other hand ‘facts and circumstances’ approaches are too complex and administratively burdensome.
Applying the residual profit split method to allocate market taxing rights is unworkable.
The global inclusion and base eroding payments proposals infringe sovereign taxing rights, negate legitimate tax incentives and will need an unrealistically high degree of consensus to work.
For a more in depth synthesis and overview of the public comments, see my article OECD Weighing Extensive Input on Digital Economy in Tax Notes International, May 6, 2019.
*Addressing the Tax Challenges of the Digitalisation of the Economy, OECD, 2019. Public comments can be found here
border adjustment tax
parent subsidiary directive
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