Mutual Agreement Procedure (MAP) provisions in OECD and UN-styled tax treaties do not mandate that the disputes arising from the application of the treaty provisions actually be settled. These clauses merely require that the two tax authorities use their best endeavours. For some tax payers this ‘toothless’ provision has seen their claims in such a … More 12 Practical Guidelines for Managing Tax Treaty Arbitration.
(Image:www.defenders.ca) Ireland is not a tax haven and has never been one! So says the secretary-general of the Organization for Economic Co-operation and Development (OECD), Dr Angel Gurria. Seriously??!! Dr Gurria was responding to an announcement made in Brussels that investigations into the tax systems of Ireland, the Netherlands and Luxembourg are to be carried … More Ireland Has Friends in High Places!
The U.S ranks 94th out of 100 on the Tax Attractiveness Index (TAI); is the worst performer of all G8 countries; and of its G20 colleagues, it only managed to out-rank Argentina, South Korea and Indonesia. Little wonder perhaps that U.S multinationals have found better tax planning opportunities in the index’s top 10 highest ranking … More Why America Might Need Our Sympathy.
..and frankly there is nothing wrong with that. Forgetting for the moment, and yes I know it is near impossible, strictly speaking, if according to the research findings of Professor James Stewart, from Dublin’s Trinity college, companies in Ireland paid tax of 4.2% on more than $100bn of net profits in 2008, that, I am … More Ireland Admit It…You Are a Tax Haven.
Don’t blame the IMF. True, one of their technical assistance teams,in a November 2012 report, completely rewrote Mongolia’s model tax treaty and cautioned that its existing treaties – in particular the one with the Netherlands – were “problematic” and recommended “immediate action” be taken because the agreements were costing the government much needed tax revenue; … More Why is Mongolia Cancelling its Tax Treaties?
Four years after Iceland let its banks fail by refusing to underwrite US$85billion in debt representing six times the country’s gross domestic product; the country’s economy has grown by 3% this year and expects a budget surplus by 2013. In addition, compared to other European countries affected by the 2008 financial crisis unemployment in Iceland … More Whatever Happened to Iceland: The Poster-Child of National Financial Ruin?