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December 14, 2017
A suite of mutually reinforcing measures with an overall focus on resolution at the earliest point in time is the ultimate goal for taxpayers and tax authorities. Achim Pross, Sandra Knaepen and Mark Johnson of the OECD describe the organisation’s comprehensive dispute resolution agenda, both within and beyond the BEPS project.
August 23, 2017
The tax status and characterisation of passive holding companies has gained renewed interest with Article 7 of the OECD’s Multilateral Instrument (MLI) containing some reference to these entities. Mauro Manca of Giovannelli e Associati looks at how these structures can still work if there are sound organisational reasons in the MNE structure.