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DCTR for VAT: The Global Shift to Real-Time Compliance — And Why the Caribbean Should Pay Attention

January 16, 2026by Dr Dawkins Brown

VAT/GST administrations around the world are steadily moving from periodic, retrospective reporting toward near real-time visibility of transactional activity. The catalyst is a family of reforms commonly grouped under Digital Continuous Transactional Reporting (DCTR)—a model in which VAT-registered businesses are required to transmit invoice data (or the invoice itself) to the tax authority on a...

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When Business Deductions Disappear: Lessons from a U.S. Tax Court Case for Global Entrepreneurs

December 2, 2025by Dr Dawkins Brown

Running a business across borders can be exciting and profitable — but when tax compliance is handled casually, it can also be very expensive. A recent decision of the United States Tax Court involving a married couple and their Malaysian engineering business is a powerful reminder of how quickly business expense deductions can be denied...

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Designing Competitive but Compliant IP and Incentive Regimes in Small Open Economies

November 28, 2025by Dr Dawkins Brown

Small open economies – including many in the Caribbean – have long relied on tax incentives and preferential regimes to attract investment, especially in finance, technology, and other intangible-rich sectors. But the world has changed. The OECD/G20 BEPS project and the Corporate Tax Statistics 2025 reveal a landscape where intellectual property (IP) and tax incentives...

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From BEPS to Pillar Two: How Anti-Avoidance Rules Are Reshaping Corporate Tax Planning

November 28, 2025by Dr Dawkins Brown

1. A New Era for Corporate Tax Strategy Over the past decade, the global tax landscape has shifted from rate competition to rule tightening. The OECD/G20 Base Erosion and Profit Shifting (BEPS) project has rolled out a comprehensive set of anti-avoidance measures, and now Pillar Two’s global minimum tax is adding another powerful layer of...

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Incentivising Innovation: Are R&D Tax Incentives Worth the Complexity?

November 28, 2025by Dr Dawkins Brown

Innovation is no longer optional. Whether you’re a regional bank building new digital channels, a manufacturer automating production, or a telecom operator investing in 5G and data platforms, research and development (R&D) and broader innovation spend increasingly sit at the heart of competitive advantage. The question for boards and CFOs is not just how much...

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Beyond the Headline Rate: Using Effective Tax Rates to Drive Smarter Investment Decisions

November 28, 2025by Dr Dawkins Brown

For years, many boards and CFOs have judged tax competitiveness by one number:the statutory corporate income tax rate. But the OECD Corporate Tax Statistics 2025 make one thing very clear: that single rate often tells you surprisingly little about the real tax cost of investment. Across jurisdictions, effective tax burdens can differ sharply from headline...

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Fixing Drafting Errors from the Bench: Tax Certainty, Legislative Gaps, and the Role of the CCJ

November 27, 2025by Dr Dawkins Brown

In tax planning conversations, you still sometimes hear this line: “Yes, that looks like a gap in the law. But if Parliament didn’t write it in, the court can’t put it there. So we’re safe.” After the Bank of Nova Scotia v Comptroller of Inland Revenue (Saint Lucia) decision, that comfort looks increasingly fragile. In...

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Branches, Head Offices, and Withholding Tax: Treating One Legal Person as Many for Tax Purposes

November 26, 2025by Dr Dawkins Brown

In company law, a branch and its head office are the same legal person. There is no separate share capital, no separate legal personality, no “other company” at the other end of the transaction. Yet, in the recent Bank of Nova Scotia v Comptroller of Inland Revenue (Saint Lucia) decision, the Caribbean Court of Justice...

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From Reimbursements to Revenue: The Tax Re-Characterisation Risk After BNS v Comptroller of Inland Revenue

November 26, 2025by Dr Dawkins Brown

For years, “reimbursement” has been one of the most comforting words in intragroup accounting. If a local branch or subsidiary simply “reimburses” head office or a regional hub for costs incurred on its behalf—at cost, with no margin—surely that is tax neutral? No profit, no gain, no income. Just a wash-through number. The recent decision...

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Branches Under the Microscope: What the CCJ’s BNS Ruling Means for Cross-Border Management Charges

November 26, 2025by Dr Dawkins Brown

The recent decision of the Caribbean Court of Justice (CCJ) in The Bank of Nova Scotia v Comptroller of Inland Revenue (Saint Lucia) is not just another tax case for lawyers to debate. It is a clear signal that tax authorities and courts across the Caribbean are ready to scrutinise cross-border payment flows—especially management and...

Newer Posts

Older Posts

DCTR for VAT: The Global Shift to Real-Time Compliance — And Why the Caribbean Should Pay Attention

When Business Deductions Disappear: Lessons from a U.S. Tax Court Case for Global Entrepreneurs

Designing Competitive but Compliant IP and Incentive Regimes in Small Open Economies

From BEPS to Pillar Two: How Anti-Avoidance Rules Are Reshaping Corporate Tax Planning

Incentivising Innovation: Are R&D Tax Incentives Worth the Complexity?

Beyond the Headline Rate: Using Effective Tax Rates to Drive Smarter Investment Decisions

Fixing Drafting Errors from the Bench: Tax Certainty, Legislative Gaps, and the Role of the CCJ

Branches, Head Offices, and Withholding Tax: Treating One Legal Person as Many for Tax Purposes

From Reimbursements to Revenue: The Tax Re-Characterisation Risk After BNS v Comptroller of Inland Revenue

Branches Under the Microscope: What the CCJ’s BNS Ruling Means for Cross-Border Management Charges

June 3, 2026Board Minutes and Tax Substance: Why Documentation Can Make or Break a Holding Company Structure

June 3, 2026When Is a Holding Company a Conduit? Understanding Beneficial Ownership and Anti-Avoidance Risk

June 3, 2026Substance Beats Formality: What the Milan Tax Court’s Luxembourg Holding Ruling Means for Cross-Border Tax Planning

June 1, 2026The Hidden Systems Challenge of IFRS 20: Why Data, Controls and Audit Readiness Matter

June 1, 2026IFRS 20 and EBITDA: Why Lenders, Investors and Boards Must Pay Attention

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