As stated in a previous comment[1], there is currently the generalized consensus that the basic strategic objective of a modern Tax Administration (TA) is to increase the levels of taxpayer voluntary compliance, by means of two main lines of action. These are: by affording facilities to those who wish to…
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In a modern office with large windows and designer furniture located in a central street in a Latin American capital. The telephone rings. Saul pick up the handset. His assistant tells him that Mr. Gómez, very nervous, is asking to speak to him urgently. Saul: Saul listening. Gomez: Saul I…
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During the last 26th and 27th of June, the “International Seminar on Tax Justice” was held in Quito, Ecuador; on occasion of the celebrations for the 60 years of tax justice in that country, organized by the Judicial Council, the School of the Judiciary, the Simon Bolivar Andean University and…
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The PPT and the EU Standard of Good Tax Governance In a recent article written by this author on the standard of good governance in tax matters for third (non-EU) countries the implications of the BEPS 4 Minimum Standards for third countries was analyzed. The ECOFIN Council has decided in…
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One of the main difficulties in the application of the transfer pricing methods to evaluate compliance with the arm’s length principle is the availability of comparable transactions. In the absence of internal comparable transactions, usually the method used is the Transactional Net Margin Method (TNMM), which was initially considered a…
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Background As of June 2019, 129 jurisdictions/countries have committed to the implementation of the BEPS 4 Minimum Standards including the PPT. However, one question that remains to be dealt with is how countries see the interaction between the domestic GAARs, treaty GAARs and the PPT of Action 6? Before the…
11,340 total views, 10 views today