Canada, Direct taxation, Double Taxation, Individuals, International Tax Law, MAPs and APAs, OECD, OECD MC Convention, Personal income tax, Tax Treaties, UN Tax Convention, Uncategorized, Unitary Taxation, United States

(Temple Tax Chambers; King’s College London)/ /Leave a comment

Art 23 of the OECD and UN Model treaties are seldom exactly followed in state treaty practice. More often, the basic principles of relief by credit or exemption in arts 23A and B are tailored to meet specific requirements of contracting states.  The United States is a case in point. Since it taxes its citizens…

ESG, United Nations Sustainable Development Goals

(Full Professor at Tilburg Law School)/ /Leave a comment

1. Sustainability, SDGs and ESG Sustainability is a highly debated topic in a world facing many environmental and social challenges. Governments promote sustainability and sustainable development. But these concepts seem to be container concepts. The UN Sustainable Development Goals (SDGs) give something to hold on. Sustainability is fleshed out in the 17 United Nations SDGs….

Customs and Excise, Direct taxation, EU law, Indirect taxation

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University)/ /Leave a comment

Highlights & Insights on European Taxation Please find below a selection of articles published this month (December 2024) in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV. The journal offers extensive information on all recent developments in European Taxation in the…

India, MFN, OECD, Switzerland, Tax Treaties

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Switzerland has suspended the application of the most favoured nation clause contained in the protocol to its 1994 tax treaty with India. This was done in response to the Supreme Court of India’s judgement in Nestlé.[1] This action appears to have raised a number of legal questions with respect to reciprocity in tax treaty interpretation…

CJEU, Hungary, VAT

(Catholic University, Lisbon) and (VdA, Lisbon)/ /Leave a comment

The Novo Nordisk AS ruling (C-248/23), issued by the CJEU on September 12, 2024, is the latest in a string of decisions on the VAT regime of rebate schemes in the pharmaceutical sector. In this ruling the CJEU looks at a new question: whether a tax on the sales of pharmaceutical companies can be qualified…

Customs and Excise, Direct taxation, EU law, Indirect taxation

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University)/ /Leave a comment

Highlights & Insights on European Taxation Please find below a selection of articles published this month (November 2024) in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV. The journal offers extensive information on all recent developments in European Taxation in the…

Italy, OECD, Pillar I, Pillar II, United Nations

(Associate Chiomenti)/ /1 Comment

On 22 November 2024 more than 300 tax experts gathered in Rome for the first Italian International tax conference organized by Italian Association of Joint Stock Companies (Assonime). Under the patronage of the OECD, the European Commission and the Italian Ministry of Economy and Finance (MEF), the event brought together business representatives and institutions to…

Environmental tax policy, Greenhouse gas strategy, Shipping

(Assistant Professor, School of Law and Government, Dublin City University) and (Associate Dean, Faculty of Law, and Research Director Centre for Advanced Studies in Environmental Law and Policy(CASELAP), University of Nairobi)/ /Leave a comment

Dr. Goran Dominioni[1] and Prof. Collins Odote[2] Over millennia, maritime transport has played a vital role in the flourishing of human civilization, allowing for long-distance commerce and cultural exchange. Up to the Industrial Revolution, ships were propelled primarily by humans and wind power, but since the 19th century, the industry shifted towards the use of…

Apple, European Court Of Justice, State Aid, Subsidies, Tax, Taxation

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This blog post was first published on the Kluwer Competition Law Blog.   On September 10, 2024, the European Court of Justice (ECJ or Court) sided with the European Commission (Commission) and ruled that two Irish subsidiaries of Apple Inc. received unlawful state aid from Ireland in the form of a tax advantage (Case C-465/20…

Customs and Excise, Direct taxation, EU law, Indirect taxation

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University)/ /Leave a comment

Highlights & Insights on European Taxation Please find below a selection of articles published this month (October 2024) in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV. The journal offers extensive information on all recent developments in European Taxation in the…

CJEU, EU law, OECD

( PwC Netherlands, Lazarski University and Singapore Management University)/ /Leave a comment

The author would like to give thanks to Professor Daniel Gutmann, Professor Georg Kofler, and Simon Whitehead for an engaging and intellectually stimulating exchange of views on the CJEU’s judgment in X BV case through the emails. This post benefitted from it. However, the author is solely responsible for its content and no views expressed…

Uncategorized

(General Editor of Intertax)/ /Leave a comment

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Tamir Shanan, Doron Narotzki & Noam Zamir, A Time to Institutionalize the International Tax Regime The paper proposes replacing the existing and outdated decentralized international tax system with a centralized tax authority that would…

Uncategorized

(General Editor EC Tax Review and tax adviser at Ernst & Young Belastingadviseurs LLP)/ /Leave a comment

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Han Kogels, Will the Road to Carbon Neutrality Become Even More Bumpy Than Ever? The first-ever global stocktake of what has been achieved and what still must be achieved since the 2015 Paris Agreement…