Is Article 5 to blame?

Google uses Article 5 of the UK/Ireland DTA to justify its tax arrangements, but is there room for review, asks Andrew Goodall

Amid the controversy surrounding the tax affairs of Google and other US-based multinationals there has been relatively little discussion of the Organisation for Economic Cooperation and Development's (OECD) work to plug 'gaps' in the international tax system. The OECD warned in February that legal but 'aggressive' tax strategies employed by some multinationals were eroding the tax base of many countries and that the integrity of the system was at stake; at the same time, it cautioned against unilateral and uncoordinated action by individual countries, which could result in the risk of 'multiple' taxation and have a negative impact on investment and employment.

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