Maarten de Wilde* Summary On March 31, 2021, U.S. President Biden released his ‘American Jobs Plan’, an ambitious proposal for large scale public investments in infrastructure and other priorities. That same day the American President announced plans to offset the costs of these investments with U.S. corporate tax increase proposals: the ‘Made in America Tax…
(The full version will be published in Intertax, vol. 49, 2021, issue 5) Nicole Gubbels, Assistant Professor (Vrije Universiteit Amsterdam and Fiscal Institute of Tilburg University, the Netherlands) Society has changed considerably over the past 50 years. Whereas, previously, most people got married, had several children during the marriage, and divorce was still relatively rare,…
On 1 July 2019, the Dutch tax ruling practice was revised to align it with EU and international standards and recommendations as well as to increase its openness and transparency. In this respect, the Dutch tax authorities (DTA) now publish anonymized summaries of advance pricing agreements and advance pricing agreement (APA) requests. This month, Intertax…
Last month witnessed the release of the operative part of the award of the Permanent Court of Arbitration (‘PCA’) in the dispute initiated by Vodafone’s Dutch entity against Government of India (‘GOI’) under the India-Netherlands Bilateral Investment Treaty (‘Indo-Dutch BIT’). It is understood that the detailed award has been withheld in view of the request…
In last month’s blog I promised to address the treaty aspects of Davies and Others v HMRC [2020] UKUT 67 (TCC). The case concerned UK resident individuals who each took out a life insurance policy with a Bermuda insurer under which their entitlements were linked to a Mauritian company that developed land in the UK….
Equality is one of the core values of modern democratic societies. It is no accident that equality featured in opening preamble to the United States Declaration of Independence in 1776 and the first article of both the French Declaration of the Rights of Man in 1789 and the United Nations Universal Declaration of Human Rights…
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…
DNB (Dutch Central Bank) issued on July 2 2019 a Guideline entitled “Good practices tax integrity risks at clients of banks” (Good practices fiscale integriteitsrisico’s bij cliënten van banken). The Financieel Dagblad (Dutch financial newspaper) published an article on August 7 on the topic. The editor’s comment in the August 8 paper concludes this is…
