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  • Many of the BEPS actions have resulted in agreed changes to the OECD Model Tax Convention. These changes must be implemented swiftly, efficiently and consistently to ensure that treaty-related BEPS issues can be addressed. The ordinary way for implementing such treaty changes would be for each country to renegotiate its existing bilateral tax treaties, which would take decades to complete given the size of the existing network of more than 3,000 tax treaties globally. The project therefore included a commitment to develop a multilateral instrument to sidestep this problem. Jesse Eggert and Evelyn Lio explain.
  • Anton Zykov Alexander Grinko Since the Supreme Commercial Court's ruling on November 15 2011 in the Severny Kuzbass case, Russian commercial courts have widely adopted the OECD Model Convention, commentaries on the articles of the Model Convention, and reports adopted by the OECD Council, as the basic framework documents that set out the general principles and approaches to avoiding double taxation.
  • The 2013 BEPS Action Plan recognised that “actions to counter BEPS must be complemented with actions that ensure certainty and predictability for business”. Edward Barret and Evelyn Lio track the work of Action 14 of the BEPS Action Plan, which called for work to improve the effectiveness of the mutual agreement procedure (MAP) and thereby address obstacles that currently prevent countries from solving treaty-related disputes and minimise as much as possible elements of uncertainty related to the interpretation and application of novel rules resulting from the other work on BEPS issues.
  • Rene Zulauf Andreas Fross Globalisation has played an important role in the way multinational enterprises (MNEs) are structured today. Group financing is centralised at a regional or global level to benefit from numerous cost synergies, including taxes.
  • Kuwait has implemented new initiatives to help it compete for foreign investment, and further reforms could well be on the way.
  • Ivana Blagojevic On September 4 2015, the Serbian Government approved the draft Treaty for Avoidance of Double Taxation, signed between Serbia and Norway on June 17 2015. The treaty's entry into force is pending ratification from both parties.
  • Jelena Zivkovic Ivan Petrovic As a young country with a small but open economy, Montenegro is steadily adopting various business incentives, with the objective of attracting reputable foreign investors, particularly in selected industries.
  • Tim Stewart A Bill has been introduced to the New Zealand Parliament that, if enacted, will apply goods and services tax (GST) to remote services and intangibles (including e-books, music, videos and software) supplied by non-resident suppliers to New Zealand resident consumers.
  • Marta Szafarowska Those dealing with VAT in other EU countries are surprised that, so far in Poland, taxpayers making both VATable transactions as well as activities that do not fall within the VAT regime, are entitled to deduct the whole amount of VAT resulting from purchases of goods and services where direct allocation to VATable and non-VATable activities is not possible.
  • Because tax doesn’t have to be taxing. A less-than-serious look back at some of the quirkier tax stories from the past month.
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