If we share the affirmation of Judge O. Wendell Holmes that “taxes are the price that you have to pay to live in a civilized society“, we must not forget an important element: those who pay taxes. The goal of this brief intervention is not to abound in the role…
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Since the signature of the Climate Agreement of Paris[1] adopted on December 15, 2015, an increasing number of countries have approved laws with the aim of reducing their greenhouse gas (GHG) emissions. A new study by researchers and staff of the United Nations Framework Convention on climate change, the UNFCCC,…
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In the tax administration field (TA), when we talk about the function of assistance to taxpayers, we are generally referring to all the help that is offered so that they can comply with their tax obligations, either presentation of the tax returns, compliance with information regimes, adherence to a regime…
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We live in an era where technology enables automatization of many processes that for decades and even centuries have been human-based, including taxation. The term “Real-Time Economy” was coined at a Finnish university Aalto as “An environment where all the transactions between business parties are in digital format, increasingly automatically…
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The sustained increase in the levels of tax litigation represents a serious problem for many countries (Thuronyi and Espejo, 2013. IMF, Legal Department). This is especially true when such litigation levels cause, among other aspects, the multiplication and prolongation of conflicts in time; surcharge of the judicial system; they increase…
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Tax effects of hybrid arrangements In order to facilitate the understanding of the problem that is addressed in the Action 2 of the BEPS Action Plan, treated in my previous post, we are going to provide some examples. The existence of a disagreement between two countries over who or what…
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