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…
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…
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& Noam Zamir, A Time to Institutionalize the International Tax Regime The paper proposes replacing the existing and outdated decentralized international tax system with a centralized tax authority that would…
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…
Highlights & Insights on European Taxation Please find below a selection of articles published this month (September 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…
After the silent collapse of Pillar One earlier this summer, as it now seems, the question as to what’s next seems to be moving up business agendas and political agendas. On an informal meeting of tax practitioners from business and consultancy in Rotterdam, the Netherlands, on 24 September 2024, the author of the current blog…
Introduction The Indian GAAR (Chapter X-A of the Income-tax Act, 1961 [‘the Act’])) was introduced in the Finance Act 2012 and came into effect on April 1, 2017. Prior to the introduction of GAAR, Indian courts have dealt with tax avoidance cases and have developed principals, also referred to as judicial doctrine to combat arrangements…
The terms of reference (ToR) adopted by the Ad Hoc Committee[i] will be submitted to the UN General Assembly and voted during its 79thth session – taking place from 10 to 24 September 2024 in New York. If these terms of reference are adopted, the negotiating committee will be expected to submit a final text…
Highlights & Insights on European Taxation Please find below a selection of articles published this month (August 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…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Vladimir Starkov, The Need for Plan B: Comments As of mid-July 2024, the Multilateral Convention (MLC) on Amount A seems to have received a lacklustre response from the majority of stakeholders, despite the extensive…
One strategic response of countries to the Global Minimum Tax (the GloBE rules) would be restructuring their tax incentives. The top-up tax effectively nullifies any tax incentive that brings the effective tax rate below 15%. This would push countries to redesign tax incentives that would otherwise produce an effective tax rate below 15%. In a…
The Pillar 2 initiative (GloBE and QDMTT) has been seen as the end of using low effective corporate income tax rates (either by virtue of low nominal corporate income tax rates and/or through the use of tax incentives) as a means to attract foreign investors. Sacrifices made by the host country in terms of lower…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Rita De La Feria, What Is Tax Fairness? In the last two decades, the term ‘fair taxation’ has become ubiquitous in the European public debate. From a political economy perspective this increased popularity…
Coca-Cola announced that it would appeal to the Eleventh Circuit Court of Appeals, based in Atlanta, the Tax Court’s final entered decision of August 2, 2024, in favor of the IRS’ determination of $9 billion of transfer pricing adjustments and the validity of the IRS’ blocked income regulations.[1] The 240-page Coca-Cola 2020 Tax Court decision[2]…
