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BEPS – some questions and check the box

Reading through the BEPS paper and in particular the examples at pages 73 to 81 of the paper and listening to the debate in Paris on 26 March poses for me some interesting questions : Can business oppose the elimination of double non taxation? Can one address BEPS without changing the check the box rules? […]

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BEPS – some specific issues

The BEPS project moves forward and their barely seems to be a week when there isn’t a conference or meeting about it . But all this activity does not necessarily shed much light if the shape and purpose of the project is being conducted in a manner which could not be described as transparent. There […]

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NGOs – what is their target?

I’ve been thinking about the targets which NGOs choose in their tax campaigns in the light of the BEPS project. The two main targets have been SAB Miller and ABF. Looking at their accounts, I find this a little odd. Associated British Foods (ABF) has a tax rate of 24.8% with a benefit for rates […]

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NGO code of conduct

There has been an interesting set of exchanges about whether NGOs need to have a code of conduct for their publications about tax. I certainly think that a voluntary code would make sense. In discussing this I’ll run through a post on this subject by Martin Hearson. Martin wrote (I’ve not included the discussion about […]

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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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Starbucks, Amazon and Google and Treaty Policy

As the Public Accounts Committee prepares to hear the big 4 on Thursday 31 January, I’ve been thinking more about the fallout from their last hearing. I attended the Vienna conference “Developing a Tax Environment for Growth and Competitiveness” and there was plenty of focus on the Starbucks/Amazon/Google issues. The conference was held under Chatham […]

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Can a “green” company engage in tax avoidance?

I keep rereading a blog by James Murray on the Business Green website . James basically focuses on whether  a “Green” company can engage in tax avoidance without damaging its green credentials? He focuses on Google and Starbucks as he describes Amazon as “having one of the most widely criticised approaches to environmental issues and […]

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Emission Trading permits and Tax

I’m pleased that Business Europe has made a submission to the OECD on this subject which I’ve uploaded onto the document section. I helped to get this issue onto the OECD agenda in 2009 and led the work which BIAC did in this field. It is an important field if Emission Trading is to be […]

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