The present publication is concerned with the process of thin capitalisation in the countries of OECD. Two methods for financing companies are discerned in relation to this phenomenon, i.e. debt and equity financing. The tax-related consequences of the method of equity financing of companies are...

The following paper explores the issue of thin capitalisation in Organisation for Economic Co-operation and Development (OECD) member countries. There are two methods used by financing companies that are strongly related to this phenomenon: debt and equity financing. The tax-related consequences...

Observers of international tax rules have long conflated two distinct effects of the foreign tax credit on multinational firms: the effect on the incentive to invest abroad and the effect on foreign tax sensitivity. With national welfare as the policy objective, we discuss how a burden neutral...

In this article, the author examines, through numerical examples, the effects would EU Member States subject taxpayers – both residents and non-residents – deriving income from domestic sources, to unlimited income taxation whilst granting double tax relief for foreign income under a...

This letter responds to the request in Notice 2017-28 for public comment on recommendations for items that should be included on the 2017-2018 Priority Guidance Plan. Recommendations in this letter cover various treaty abuse situations

Typically, the tax treaty entitlement to fiscally transparent entities (‘FTEs’) has been a matter of debate in the arena of international tax. FTEs are not taxed at the entity level but at the level of the persons who have an ownership interest in that entity. Hands down, it is one of the...

International tax policy experts often mistakenly conflate two distinct margins: (1) the overall tax burden on outbound investment, and (2) the marginal reimbursement rate (MRR) for foreign taxes paid, which is 100 percent under a foreign tax credit system, but equals the marginal tax rate for...

In regard to "Options to address the broader direct tax policy challenges", I suggest that the Task Force consider several matters:- Practical "best practice" approaches for determining some minimal level of digital presence that would be treated as a PE. The Task Force should recommend language...