We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Tina Ehrke-Rabel & Barbara Gunacker-Slawitsch, Tax Administration AI: The Holy Grail to Overcome Information Asymmetry in Tax Enforcement?   Liberal democracies are based on the concept of the free person who is a…

*This post was first published on the website of Maastricht University*   In recent weeks the tax world gave a lot of attention to how President Trump blew up some serious advancements in international tax law, long in the making. One of those advancements was the introduction of a minimum tax on profits of the…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Axel Cordewener, ‘Windfall Taxes’ under Regulation (EU) 2022/1854: Soon Gone With the Wind? Regulation (EU) 2022/1854 obliged Member States to introduce, on a temporary basis, a cap on market revenue of certain electricity…

“When I use a word,” Humpty Dumpty said in rather a scornful tone, ” it means just what I choose it to mean, neither more nor less.” (Lewis Carroll, Alice through the Looking Glass) Prior to the OECD’s 10 year project on attribution of profits to permanent establishments, there were very few reported cases on…

Highlights & Insights on European Taxation Please find below a selection of articles published this month (January 2025) 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…

Summary While the U.S. has pulled out from the Global Tax Deal early 2025, threatening taking countermeasures, the latest batch of Inclusive Framework (IF) documents state several times that the IF countries accept the Pillar Two Model Rules and guidance and everything that is devised within the IF context as part of the ‘common approach’…

Within hours of his appointment, Donald Trump issued a memorandum in which he rejects the Global Tax Deal conceived by the OECD/G20. The new US president stresses that it has “no force or effect within the United States”  without an act by the Congress adopting the relevant provisions of the agreement. The memo is bluntly…

Art 23 of the OECD and UN Model treaties are seldom exactly followed in state treaty practice. More often, the basic principles of relief by credit or exemption in arts 23A and B are tailored to meet specific requirements of contracting states.  The United States is a case in point. Since it taxes its citizens…

1. Sustainability, SDGs and ESG Sustainability is a highly debated topic in a world facing many environmental and social challenges. Governments promote sustainability and sustainable development. But these concepts seem to be container concepts. The UN Sustainable Development Goals (SDGs) give something to hold on. Sustainability is fleshed out in the 17 United Nations SDGs….

Highlights & Insights on European Taxation Please find below a selection of articles published this month (December 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…

Switzerland has suspended the application of the most favoured nation clause contained in the protocol to its 1994 tax treaty with India. This was done in response to the Supreme Court of India’s judgement in Nestlé.[1] This action appears to have raised a number of legal questions with respect to reciprocity in tax treaty interpretation…

The Novo Nordisk AS ruling (C-248/23), issued by the CJEU on September 12, 2024, is the latest in a string of decisions on the VAT regime of rebate schemes in the pharmaceutical sector. In this ruling the CJEU looks at a new question: whether a tax on the sales of pharmaceutical companies can be qualified…

Highlights & Insights on European Taxation Please find below a selection of articles published this month (November 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…

On 22 November 2024 more than 300 tax experts gathered in Rome for the first Italian International tax conference organized by Italian Association of Joint Stock Companies (Assonime). Under the patronage of the OECD, the European Commission and the Italian Ministry of Economy and Finance (MEF), the event brought together business representatives and institutions to…