The corporate reform package proposal published on 25th October, 2016 provides three new proposals to provide for a more modern and fairer tax system for business , to close loopholes between EU countries and non-EU countries and to provide new dispute resolution rules to relieve problems with double taxation for businesses. For more information and to read the full package see here.
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Perhaps have a look at (current) art 2(3)?…
The does not seem correct. All DTAs are about income or capi…
As alluded to above in the post, the relevant non-discrimina…