Publications in 2025 by the International Tax Group
Featured Articles
Publications in 2025 by the International Tax Group
Featured Articles
Interpretation under the Multilateral Instrument (MLI) - Part 1 and 2
Part one explores the functioning of the MLI, its current design and the status of the synthesized texts. It deals with the interpretation rule of the MLI and its relationship with the interpretation rules of the Vienna Convention on the Law of Treaties.
Part two focuses on specific aspects of MLI interpretation, including the Explanatory Statement and Opinion of the Conference of the Parties, the BEPS Action Reports, the 2017 OECD Commentaries and future amendments, the impact of reservations and language issues.
Authors:
Frank Pötgens, Stéphane Austry, John Avery Jones, Philip Baker, Peter Blessing, Robert Danon, Shefali Goradia, Johann Hattingh, Koichi Inoue, Guglielmo Maisto, Toshio Miyatake, Angelo Nikolakakis, Kees van Raad, Jens Schönfeld, Richard Vann and Bertil Wiman.
The Relationship of Head Office and Its Foreign Permanent Establishments: The Current State of the Authorised OECD Approach (Part 1 and 2)
Part One of this article reviews the purpose and history of permanent establishment (PE) taxation and examined the uneven reception of the Authorised OECD Approach (AOA) across major jurisdictions.
Part Two explores the AOA’s practical impact, focusing on banks’ free capital, and addresses concerns about its asymmetry with transfer pricing rules. The article concludes with possible future developments and pathways for refining profit attribution.
Authors:
Stéphane Austry, Richard Vann, John Avery Jones, Philip Baker, Peter Blessing, Robert Danon, Shefali Goradia, Johann Hattingh, Koichi Inoue, Guglielmo Maisto, Toshio Miyatake, Angelo Nikolakakis, Frank Pötgens, Kees van Raad, Jens Schönfeld, Bertil Wiman.