Advance Pricing Agreements (APAs) are a diffused tool for taxpayers to obtain certainty in relation to the tax impact of their cross-border activities through an agreement with a tax administration in advance of such activities. APAs can be unilateral, bilateral,…
The Change of Scenery
On 1 December 2019, the von der Leyen Commission took over for the coming 5 years, and it is called to deliver on a most challenging mandate. The European identity is questioned more than ever before,…
In the year in which IAFEI celebrates its 50th anniversary, the 49th Congress of IAFEI will take place in Italy in Matera (2019 European capital of culture) on October 25th and 26th.
The main topic is quite inviting: “An holistic…
While data-centred business models are claiming an ever-growing share of worldwide revenue, regulatory efforts to identify proper tax rules for the relevant activities are intensifying. It is questionable whether or not the proposals currently on the table capture the distinctive…
lnternational tax disputes arise, in principle, where
there is a bilateral or multilateral treaty for the avoidance of double taxation (hereinafter “Double Tax Convention” or “DTC”) or an equivalent instrument and
the contracting jurisdictions exercise their taxing power in a…
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