Tax authorities have relied on informers for investigative leads perhaps since taxes were first imposed. In the 21st Century high profile cases of theft of taxpayer information by employees of service providers including banks and professional firms have provided data not only of interest to tax authorities but also as a driver of international tax…

1. Introduction To be able to compete successfully in international markets, companies need to turn their R&D results fast and effectively into marketable products. Thus, besides the development (enhancement, maintenance, exploitation) of IP, its protection is of essential importance for companies. In order to ensure maximum legal protection, companies oftentimes formally register their IP assets…

Back in 2000, computer gaming was revolutionized. Instead of sports games, ego shooters or other genres, people caught an interest in ‘virtual living’.  Games offered an extensive life simulation. To an – at that time – unprecedented degree, people could live their lives virtually. Disregarding the why behind what drives players, it is undeniable that…

HMRC v Embiricos [2020] UKUT 370 (TC) reflects a common issue that arises in connection with tax investigations or audits of internationally mobile individuals. Mr Embiricos  filed his tax returns on the basis that he was resident, but not domiciled in the UK. On that basis, he was entitled to the remittance basis of taxation….

Introduction Let’s assume the following situation: ParCo is the parent company of a multinational group with its residence in Switzerland and engaged in the automotive business. It developed an innovative battery technology. Due to the high density of competition and rivalry, ParCo is interested in having its innovative technology protected through a patent. For this…

In many member states’ tax law, mutual investment funds are relieved from double taxation, i.e. proceeds from investments are taxed only once even though they are earned on two levels: first at the level of the fund, and then at the level of the owners of the fund. The logic behind this is that mutual…

According to an undisclosed policy paper that is currently circulated within the OECD, the German government is promoting an internationally coordinated reform of corporate taxation. Specifically, Germany proposes an effective minimum tax on the profits of multinational companies. Complex, easy to manipulate and unfair – there is widespread discontent with the current system of international…