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Opinion Statement FC 14/2016 on the OECD Discussion Draft on Branch mismatch structures (BEPS Action 2)

Opinion Statement FC 14/2016 on the OECD Discussion Draft on Branch mismatch structures (BEPS Action 2)

by | Sep 16, 2016

This Opinion Statement by the CFE Fiscal Committee relates to the OECD discussion draft “BEPS Action 2: Branch Mismatch Structures” (hereinafter the “Discussion Draft”), released for public consultation on 22 August 2016 as a follow-up to the Action 2: 2015 Final...
Opinion Statement FC 14/2016 on the OECD Discussion Draft on Branch mismatch structures (BEPS Action 2)

Opinion Statement FC 13/2016 on the OECD Discussion Draft (BEPS Action 7) Additional guidance on the attribution of profits to permanent establishments

by | Sep 16, 2016

This Opinion Statement relates to the OECD Discussion Draft “Additional guidance on the attribution of profits to permanent establishments” released on 4 July 2016 on BEPS Action 7 (“Preventing the artificial avoidance of permanent establishment status”)....
Opinion Statement FC 14/2016 on the OECD Discussion Draft on Branch mismatch structures (BEPS Action 2)

Opinion Statement FC 12/2016 on the OECD Public Discussion Draft (BEPS Actions 8-10) Revised Guidance on Profit Splits

by | Sep 16, 2016

  This Opinion Statement relates to the OECD Discussion Draft “Revised Guidance on Profit Splits” on BEPS Actions 8-10 (“Assure that transfer pricing outcomes are in line with value creation”), released on 4 July 2016, and follows up on CFE’s previous...
Opinion Statement FC 14/2016 on the OECD Discussion Draft on Branch mismatch structures (BEPS Action 2)

Opinion Statement PAC 4/2016 on the Regulation of cross-border professional services

by | Aug 16, 2016

Opinion Statement PAC 4/2016 on the Regulation of cross-border professional services supplementing the CFE response to the electronic consultation on the proposal to introduce a Services Passport and address regulatory barriers in the construction and business...
Opinion Statement FC 14/2016 on the OECD Discussion Draft on Branch mismatch structures (BEPS Action 2)

Opinion Statement ECJ-TF 2/2016 on the Case C-18/15, on the admissibility of gross withholding taxation of interest

by | Aug 15, 2016

This is an Opinion Statement prepared by the CFE ECJ Task Force on Case C-18/15, in which the 5th Chamber of the Court of Justice of the European Union (ECJ) delivered its judgment on 13 July 2016, following the opinion of Advocate General Juliane Kokott of 17 March...
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