Category: International law

  • The quiet BEPS revolution: Moving away from the separate entity principle

    The quiet BEPS revolution: Moving away from the separate entity principle

    For the longest time, international law has treated multinational enterprises (MNEs) as consisting of separate, independent units, rooted in separate national jurisdictions. Apple’s US corporate headquarters is distinct from its Irish holding company, which is distinct from its local national subsidiaries – even though they are all part of the same multinational group. Their reporting compliance and tax liabilities are, […]