Despite some of the headlines, Glaxo hasn’t won its transfer pricing court case in Canada. The judgement is worth reading: it’s not too technical and sets out the issues well. See also Alison Christians’ summary of the issues.
Category: The politics of international tax
Would a new article in the UN model tax treaty be a ‘fundamental change’ to international tax?
The most lively debate in the first two days of the UN tax committee meeting ended with the decision to start work on a new article for the UN’s model tax treaty that would allow developing countries to levy a tax on payments made to overseas providers of ‘technical services’. The advocates of this position… Continue reading Would a new article in the UN model tax treaty be a ‘fundamental change’ to international tax?
Why I love the United Nations tax committee, part 2
An interesting exchange at the United Nations tax committee on Monday, tinged with a certain irony. In the run up to the meeting, the United States Council for International Business had written a pretty angry letter to the Committee, copying in half the US Treasury, complaining about the committee’s new practical manual on transfer pricing… Continue reading Why I love the United Nations tax committee, part 2
Why I love the United Nations tax committee, part 1
International tax, the way countries coordinate and negotiate tax rules between themselves, is often talked about as if it’s about finding technical solutions to technical problems. But it’s not. Just as the tax system inside a country is at the absolute core of its political debate, so you can look at international tax and see… Continue reading Why I love the United Nations tax committee, part 1