Digging into Caterpillar and BEPS: Economic substance and location

April 29 2014

In the second part of her analysis of Caterpillar’s tax affairs following the company’s appearance before the Senate Subcommittee on Investigations, Mirna Screpante, tax researcher, looks at the division between the location of activities and the location of taxable profits and proposes a method for determining economic substance.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Request Access or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

A Taxing Week: Why Deloitte wins big at the ITR Awards (and your firm can too!)

Death, taxes and Deloitte hoovering up trophies at an ITR awards night. Isn’t that the saying?

Sam Sholli, September 25 2026

Podcasts

ariane calloud baker mckenzie podcast article image

Podcast: Baker McKenzie partner predicts AI audits and pillar two disputes

AI, pillar two and joint audits could define the next era of tax controversy, says Baker McKenzie tax partner Ariane Calloud

Tom Baker, September 24 2026

Indirect Tax

The growing market for insurance-backed receivable financing

Gregor McMillan of Howden explains how insurance-backed financing can help businesses and funds unlock liquidity from tax receivables and other contingent claims

Tom Baker, September 23 2026

Direct Tax

Milbank hires O’Melveny’s tax chair in New York

The arrival of Alex Anderson swiftly follows that of funds tax specialist Stuart Alter and suggests the Tier 3-ranked firm has higher ambitions

Tom Baker, September 22 2026

Direct Tax

WTS UK continues big four challenge with double tax hire

One of the two appointments is EY’s Gordon McIntosh, who becomes the big four firm’s second senior tax departure in September

Sam Sholli, September 21 2026

Indirect Tax

Beyond the headlines: Inside Fieldfisher’s successful bid for EY’s trade disputes chief

Balson's move from a Tier 1 practice to a Tier 3 competitor looks counterintuitive. The market data suggests it is anything but

Tom Baker, September 21 2026

Awards

Deloitte, KPMG, DLA Piper and Eversheds Sutherland win headline ITR Europe Awards

It was another banner year for Deloitte, which picked up more awards than any other firm at a gala ceremony held at The Londoner in Leicester Square

Sam Sholli, September 18 2026

Direct Tax

‘Difficult to read’: damning report prompts KPMG Australia to accept whistleblower failing

The big four firm has been embroiled in a scandal over partners’ misuse of confidential board papers to pitch for and win corporate audits for Westpac and Dexus

Sam Sholli, September 17 2026

Transfer Pricing

New ATO royalty withholding tax ruling: not just for technology

Drawing on lessons from the PepsiCo case, tax lawyer Paul McNab explains why the ATO's latest royalty guidance should concern multinationals well beyond the technology sector

Paul McNab, September 17 2026

Direct Tax

Strategic Business Audit and Financial Management: Analyzing Data for Profitable Growth, Magnifying glass science and technology, Graphs and dashboard

Why tax needs a new operating model

As pillar two exposes the limits of fragmented tax processes, organisations are rethinking their operating models to create the trusted data foundations that AI demands

Russell Gammon, September 16 2026