Increasingly linked by regional and global ties, national economies depend more than ever on international investments and trade. While trade and investment have become international, however, taxation has remained national, preserving and strengthening one of the few remaining barriers to...

Among the actions identified by the OECD to address base erosion and profit shifting (BEPS), one of the most challenging is Action 4, which is intended to limit base erosion effected by way of interest deductions and other financial payments. This short article reviews Canadian experience that...

This article is to examine the approach of OECD Action plan on BEPS. Because of space limitations, I shall confine myself principally to critique BEPS Action Plan and Key pressure areas. I shall also respond to some substantial issues, errors and general points. Part I - discuss about the...

Article 13 of the OECD Model tax treaty allows a source country to retain taxing rights on capital gains realized by non-residents on the sale of real (immovable) property in the source country. Recently, it has been modified to incorporate a further rule that has long been a feature of the UN...

Technological change and financial deregulation have dramatically globalised financial markets. Financial firms have developed innovative financial instruments, such as swaps and derivatives, to meet the often different global demand of investors and borrowers and have organised themselves to...