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The Virus in the ALP
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The Virus in the ALP (2020)The Virus in the ALPFive Core Problems in the Attribution of Profits to Permanent Establishments (2019)Five Core Problems in the Att…The OECD/G20 Global Minimum Tax and Dispute Resolution: A Workable Solution Based on Article 25(3) of the OECD Model, the Principle of Reciprocity and the GloBE Model Rules (2022)The OECD/G20 Global Minimum T…International Tax Coordination for a Second-Best World (Part I) (2009)Are We Heading towards a Corporate Tax System Fit for the 21stCentury? (2014)Ten Questions about Why and How to Tax the Digitalized Economy (2018)Value Creation: A Guiding Light for the Interpretation of Tax Treaties? (2020)On the Apparent Widespread Misapplication of the OECD Transfer Pricing Guidelines (2022)Indian Logistics Industry (2023)THE PRINCIPLE OF SYSTEMIC INTEGRATION AND ARTICLE 31(3)(C) OF THE VIENNA CONVENTION (2005)Qualification of Taxable Entities and Treaty Protection (2014)Tax Challenges Arising from Digitalisation – Report on Pillar Two Blueprint (2020)
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  • 2019Five Core Problems in the Attribution of Profits to Permanent Establishments48 cited

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  • 2022The OECD/G20 Global Minimum Tax and Dispute Resolution: A Workable Solution Based on Article 25(3) of the OECD Model, the Principle of Reciprocity and the GloBE Model Rules10 cited

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