Archive | March, 2014

What is a legitimate hybrid?

The Beps project has produced two technical papers on the domestic and cross border issues about hybrids. Various advisors have commented publicly. It seems to me that they start from the wrong place and protest too much – I won’t speculate on the second issue, but as I have said what is needed is a […]

Read full story Comments { 0 }

Beps and the beautiful game

As the next round of BEPS publications start to appear, two stories from the world of football made me think about the whole process of how we think about tax avoidance. They concern Uli Hoeness and by association Bayern Munich and Neymar and Barcelona. Now these two teams are amongst the true elite of club […]

Read full story Comments { 0 }