The book represents a holistic, scientific analysis of Country-by-Country Reporting (CbCR) and its implementation within Germany. It analyses questions of doubt, the regulations for the automatic exchange of information and the economic (mis)interpretation possibilities. The res…
Under the Action 13 Minimum Standard, jurisdictions have committed to foster tax transparency by requesting the largest multinational enterprise groups (MNE Groups) to provide the global allocation of their income, taxes and other indicators of the location of economic activity.…
French translation of the peer review report on treaty shopping. Action 6 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project identified treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns. It is one of the four BEPS…
Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disp…
Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disp…
BEPS Action 5 is one of the four BEPS minimum standards which all Inclusive Framework members have committed to implement. One part of the Action 5 minimum standard is the transparency framework for compulsory spontaneous exchange of information on certain tax rulings which, in …
BEPS Action 5 is one of the four BEPS minimum standards which all Inclusive Framework members have committed to implement. One part of the Action 5 minimum standard is the transparency framework for compulsory spontaneous exchange of information on certain tax rulings which, in …
Action 6 of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project identified treaty abuse, and in particular treaty shopping, as one of the most important sources of BEPS concerns. It is one of the four BEPS minimum standards that all Inclusive Framework members have comm…