This material was first published by Sweet & Maxwell Limited in Angelo Nikolakakis, Stephane Austry, John Avery Jones, Philip Baker, Peter Blessing, Robert Danon, Shefali Goradia, Johann Hattingh, Koichi Inoue, Juergen Luedicke, Guglielmo Maisto, Toshio Miyatake, Kees van Raad, Richard Vann and...

This article seeks to assess why current transfer pricing rules are the source of tax avoidance and explore some possible remedies. It places transfer pricing rules in the overall context of taxing international business income in the situation of a widely held corporate group operating in...

This article analyses the meaning of the definitions of dividend and interest in the OECD Model by reference to their historical evolution. In the dividend definition the origin of 'other corporate rights' is traced to a 1958 OEEC Working Party minute in which the same French expression used in...

This article provides critical reflections on the 2017 revision of article 4(3) of the OECD Model Convention and its Commentary regarding dual residence of persons other than individuals. These changes and their implementation warrant an assessment of their desirability, including an in-depth...

This article provides critical reflections on the 2017 revision of article 4(3) of the OECD Model Convention and its Commentary regarding dual residence of persons other than individuals. These changes and their implementation warrant an assessment of their desirability, including an in-depth...

This paper considers the structure of the transfer pricing rules in tax treaties and their modern development in the Transfer Pricing Guidelines. It discusses how tax structuring and restructuring relying on the guidelines occurred to reduce residence and source taxation and commences an...