How the Apple Settlement reflects Italian Focus on TP (including Valente Associati GEB Partners’ Contribution to the Feature)

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Published in: TP Week
Date: 12.01.2016

“Never before has the international tax arena assumed such relevance,” said Piergiorgio Valente, managing partner of Valente Associati GEB Partners. “International and European tax policy have contributed to a change of behaviours, with an impact that affects both tax authorities and taxpayers.”

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A Post-BEPS Primer for Boards: Status of Implementation of the Authorized OECD Approach into Domestic Tax Law and Tax Treaties

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By: TPA Insight

This article examines profit/loss allocation in a headquarter/branch scenario.
Part 1 discusses the actual split between a head office and branch from a theoretical perspective, discusses basic concepts derived from public international treaty law, the notion of Key Entrepreneurial Risk-Taking Functions versus Significant People Functions and the Authorized OECD Approach (AOA).
Part 2, to be published in European Taxation 9 (2015), continues to analyse the AOA, looks at the question of whether adequate capital is allocated to the branch as a fictitious separate entity and outlines court cases, tax policy and advance pricing agreement/mutual agreement procedure implications.

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A 2016 “Look-Ahead” – BEPS Implementation to Dominate International Tax Landscape in 2016 (including Valente Associati GEB Partners’ contribution to the feature)

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Published in: International Tax Review’s December/January double issue

With the final deadlines for the OECD’s BEPS Project falling at the end of this year, 2016 was always going to be a year dominated by questions about implementation. While BEPS-related activity is not the only issue on the horizon, that alone will ensure multinationals are kept busy over the next 12 months. Joe Stanley-Smith and Matthew Gilleard look through the peephole to analyse taxpayer hopes, fears and expectations for the year ahead.

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