Germany’s anti-treaty shopping rules are among the most stringent in the world, explain Markus Schümmer and Markus Buchner of Ernst & Young. This was true for the rules that applied up to 2011, and it is still the case for the revised rules that apply from 2012 onward.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
A landmark ruling on LLP taxation has clarified who truly holds ‘significant influence’ and which partnership structures are most likely to withstand HMRC scrutiny
Fresh from the UN negotiations in New York, Alex Cobham offers ITR readers a rare first-hand perspective on the future of international tax cooperation
Despite initial hopes that the reporting obligation had been suspended, compliance challenges brought by Brazil’s indirect tax reform are very much a reality