Archive | February, 2013

Spain and Limitation of Benefits

I’m grateful to Gomez-Acebo & Pombo for their analysis of the recent case on Limitation of Benefit for  0%. withholding under the EU Parent-Subsidiary Directive (AN November 8 2012). The case concerned dividends paid by a Spanish Co to a UK holdco which was ultimately controlled in Dubai. The decision at the Audienca Nacional (AN) […]

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Unitary taxation

In my previous bog about NGO policy I referred to a review of the advantages of unitary taxation and the work of the ICC (under Theo Keijzer). I spent some time as part of the Business Europe advisory group working with the EC on the CCCBT project and I have had extensive experience of how […]

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NGO agenda for tax

I was going to speak on a panel with John Chritensen at the oconference in Vienna, but John was not able to attend . I’ve since met with him for a discussion. He was very clear what the agenda of the NGOs is : 1. Effective Multilateral Exchange of Information. 2. All sector country by […]

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