Taxes are an unavoidable aspect of our lives and play a crucial role by shaping how a country grows and serves its people. Beyond being a financial obligation, taxes represent the primary source of government revenue, directly supporting social and economic objectives. The connection between tax and ESG is primarily rooted in its Social (S)…
On December 30th of last year, the Indian Income Tax Appellate Tribunal was the first “quasi judicial institution” to apply the PPT to a treaty-shopping arrangement.[1] The case concerned a dispute between a Luxembourg-based holding company, SC Lowy, and the Indian tax authorities. Facts of the case The Luxembourg holding company, SC Lowy, is owned…
The authors are winners of the Mitchell B. Carroll Prize for the last two consecutive years, as awarded at the International Fiscal Association global congresses in 2023 and 2024 in Cancún (Mexico) and Cape Town (South Africa), respectively.* The compatibility of the Undertaxed Profits Rule (UTPR) with tax treaties based on the OECD or the…
Introduction A few weeks ago, the US Trump administration announced its departure from the so-called ‘global tax deal’, which includes all negotiations at the Inclusive Framework both regarding the OECD Pillar One and Pillar Two. In practical terms, and in the exclusive context of Pillar Two (Global Minimum Tax), this means that the United States…
Highlights & Insights on European Taxation Please find below a selection of articles published this month (February 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…
The authors would like to thank Bernard Appy, Secretary for Tax Reform at the Ministry of Finance (Brazil) for his comments and inputs. It is well established in the academic literature and suggested by international organizations that a broad-based VAT reduces distortions, increases economic efficiency, promotes growth and simplifies the system (Bird et al, 2007,…
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…
