After more than 40 years, in December 2020, Italy and Switzerland signed a new agreement concerning cross-border workers. This update, part of a joint political commitment dated 2015, arrived precisely at the right time. Indeed, the pre-existent, and still in force, 1974 Swiss-Italian Agreement showed all its inconsistencies during 2020 when inappropriate rules had to…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Han Kogels, Good Intentions and a Call for Higher Speed on the Bumpy Road to Carbon Neutrality Last year, around this time, the author went into some policy measures proposed by the United…

The most recent UN Climate Change Conference in Glasgow, or COP26, attracted the attention of long-term investors. The reason for that was the announcement of the International Financial Reporting Standards Foundation Trustees concerning the creation of the International Sustainability Standards Board (ISSB).[1] The initiative aims to address one of the complaints brought up by many…

by Dr Florian S. Zawodsky and André Thoß, LL.M., EY National Office Tax Germany The use of crypto coins and tokens is on the rise. With the perception of constant and unrestrained gains in value reaching all-time highs, most national and subnational tax laws dramatically lag behind this astonishing bull run. Simple crypto coins are…

Prof.dr. M.F. (Maarten) de Wilde[1] Summary On 20 December 2021, the OECD published the announced Pillar Two Model Rules, as part of the envisaged establishment of a global 15% minimum level of company taxation for large multinationals (Pillar 2). No mechanism has been considered to provide for a parallel adaptation of countries’ tax treaty networks…

The peculiarities of German Tax Law and its potential exemptions concerning Non-Profit-Organizations (NPO’s) are only rarely of interest to a wider audience, even among lawyers, tax professionals and academics. However, a recent reform by the German legislator may have the potential to be somewhat of an exemption hereto. The transferal of funds in compliance with…

The first part of this two-piece article titled “Virtual Activities: EU VAT’s Effort to Recompose the Broken ‘Unity of Action, Time and Place’ – Part I” provided an overview of the new place of supply rules for services relating to virtual activities introduced in the VAT Directive by the compromise text for updates on VAT…

On 7 December 2021, government ministers from European Union (EU) countries gathering at the EU Council agreed on updates of the current rules governing value added tax (VAT) rates for goods and services. The new EU rules on VAT rates represent a long-awaited modernisation of the relevant provisions contained in Annex III to Directive 2006/112/CE…

The right to be free from discrimination is perhaps the single most important human right as indicated by the fact that it appears as the first article in the UN Universal Declaration of Human Rights: “All human beings are born free and equal in dignity and rights.” In the field of international taxation, article 24…

Legend has it that a medieval hero of Spain, the Castilian knight El Cid, won a battle after death when his wife strapped his dead body to his horse, knowing that his reputation as an invincible warlord would make his enemies run away in fear. Something similar is happening to Eqiom: while our tax authorities…

We are proud to announce that Dr Alice Pirlot has joined the Kluwer International Tax Blog’s team as an editor, responsible for the new section of the blog dedicated to Environmental Taxation. Dr Pirlot, who defended her doctoral thesis at the University of Louvain in 2016, is currently a Research Fellow in Law at the…

Johannes Becker and Joachim Englisch* After the international political agreement to introduce an effective country-by-country minimum tax on multinational firm profits, there are still some open questions on the design and implementation of the tax[1]. Among other elements, the OECD/G20 Inclusive Framework Statement of 8 October 2021 envisages a “formulaic substance carve-out” for deemed routine…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Polyvios Nikolaou, Mandatory Binding Arbitration: Avoiding Stalemates Over the Tax Chessboard The resolution of tax treaty disputes under the Mutual Agreement Procedure (MAP) mechanism is inherently problematic. This article examines how the introduction…