Publications

INSIGHT: Corporate Residence Post-BEPS and Global Mobility

The article appears in International Tax News, published by Bloomberg BNA.

Attribution of Profits to Permanent Establishments: Should the AOA Be Maintained as the OECD Standard?

The article appears in the International Transfer Pricing Journal January/February 2020, published by IBFD.

Implementing Key BEPS Actions: Where Do We Stand?

Gaspar Lopes Dias This book explores the various ways in which 36 countries from across the globe have implemented the key proposals emerging from the BEPS Project. Why this book? …

Investment Funds IFA Cahiers

The article appears in International Fiscal Association; Cahiers de Droit Fiscal International – Cyprus Branch Report.

Patent Boxes: The Rise, the Change or the Fall?

The article appears in Bulletin for International Taxation journal, published by IBFD.

Transfer pricing issues on back to back financing transactions

By Demis Ioannou 1. Introduction of Transfer Pricing Issues On 30 June 2017, the Cypriot tax authorities issued the Circular 05.13.001 (“the Circular”) complying with Actions 8 to 10 under …

STARR INTERNATIONAL COMPANY, INC. v UNITED STATES OF AMERICA

TAX CASE ANALYSIS STARR INTERNATIONAL COMPANY, INC. v UNITED STATES OF AMERICA Where Reported: Case No. 14-cv-01593 (CRC) August 14, 2017 Subject: Treaty Shopping. Principle Purpose Test for determining entitlement …

The Republic of Cyprus (Appellant) ν Hagop Matossian (Respondent)

George Coussoumides (Applicant) ν The Republic of Cyprus (Respondent)

Subject: Income tax – Ex gratia payment to an employee leaving a company

INSIGHT: Treaty Shopping—Is the New Principal Purpose Test a Game Changer? [PART 1]

The article appears in International Tax News, published by Bloomberg BNA.

INSIGHT: Treaty Shopping—Is the New Principal Purpose Test a Game Changer? [PART 2]

The article appears in International Tax News, published by Bloomberg BNA.

Transfer Pricing: A Year in Review – Luxembourg (2018)

The article appeared in Bloomberg Tax.