Climate change and the use of natural resources present us all with a major challenge. We all have our part in it and we can all contribute to ensure that we do not live at the expense of future generations. Various reports and goals were agreed upon internationally (e.g. Brundtland Report and Sustainable Development Goals)….

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Han Kogels, A Changing World Making the Road to Carbon Neutrality Even More Bumpy Since the Conference of the Parties (COP) in Glasgow in November 2021 (COP26) the world has changed dramatically. In February…

Corporate Taxation (CT) Federal Decree No. 47 of 2022 (UAE CT Law) Federal Tax Authority (FTA) Ministry of Finance (MoF) OECD MC Convention (OECD MC) Permanent Establishment (PE) United Arab Emirates (UAE) UN MC Convention (UN MC) 1. Introduction The United Arab Emirates (UAE) announced the introduction of a Corporate Taxation (CT) regime on 31…

Corporate Taxation (CT) Federal Decree No. 47 of 2022 (UAE CT Law) Federal Tax Authority (FTA) Ministry of Finance (MoF) OECD MC Convention (OECD MC) Permanent Establishment (PE) United Arab Emirates (UAE) UN MC Convention (UN MC) 1. Introduction The United Arab Emirates (UAE) announced the introduction of a Corporate Taxation (CT) regime on 31 January…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Rachna Matabudul, The Multilateral Instrument in Africa: A Strategic Analysis The Multilateral Instrument (MLI) was launched under Action 15 of the Base Erosion and Profit Shifting (BEPS) Project in November 2016 under the joint…

Highlights & Insights on European Taxation Please find below a selection of articles published this March 2023 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…

Executive summary: When we look at the digital economy, we tend to think of it as a global, intangible and knowledge-driven system. However, the digital economy is not only driven by patents or trademarks – so-called “intangibles” – but also driven by “resources, data and labour”. Against the background of this incomplete understanding of the…

The Italian legal system is about to launch the tax reform which will target both direct taxes on the income of individuals and companies, as well as indirect taxes including excise duties on energy products and green products. And in fact, the Council of Ministers has approved the draft enabling law for the tax reform,…

The focus of this contribution are the newly proposed rules for the sharing platform economy under the VAT in the Digital Age (ViDA) reform package, published on 8 December 2022 by the European Commission. The proposed rules[1] envisage the introduction of a new Article 28a into the VAT Directive stipulating: “Notwithstanding Article 28, a taxable…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Stefan Greil, Michael Overesch, Anna Rohlfing-Bastian, Ulrich Schreiber & Caren Sureth-Sloane, Towards an Amended Arm’s Length Principle: Tackling Complexity and Implementing Destination Rules in Transfer Pricing The arm’s length principle (ALP) is the…

Introduction On 8 February 2023, Mathias Cormann, Secretary-General of the OECD, hosted the OECD’s first  Inclusive Forum on Carbon Mitigation Approaches (IFCMA). As its name indicates and as many readers will be familiar with due to their experience with the OECD’s Inclusive Framework on BEPs, ICFMA aims to provide a ‘safe space’ for participants to…

The eternal return is an ancient philosophical concept acquiring beautiful poetic nuances in the work of Friedrich Nietzsche. Unfortunately, this fascinating circular conception of life’s events becomes vulgar when it comes into contact with such a mundane reality as that of (Tax) Law. Here, the “ewige Wiederkehr des Gleichen” would sound anything like: “Hey buddy,…

On 28 September 2022, the Organisation for Economic Cooperation and Development (OECD) published its Bilateral Advance Pricing Arrangement Manual (BAPAM).[1] The BAPAM aims to help streamline bilateral advance pricing arrangement (BAPA) programs by providing 29 best practice recommendations to resolve commonly experienced issues.[2] Advance pricing arrangements (APAs) are a prospective dispute resolution mechanism for cross-border…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Eric C.C.M. Kemmeren, Taxing Interest in the Debtor State as an Alternative to DEBRA Basically, a company can be financed by debt or equity. The general national tax systems are that interest, the…