Arbitration, Arm's Length, BEPS, Double Taxation, International Tax Law, MAPs and APAs, Norway, OECD, OECD MC Convention, Permanent Establishments, Tax Treaties, Transfer Pricing, UN Tax Convention, United Nations

(Temple Tax Chambers; King’s College London)/ /Leave a comment

Transfer pricing adjustments under Article 9 of the model treaties are the most common form of dispute that is dealt with under the mutual agreement procedure. It is for this reason that the OECD gathers and publishes statistical data on such cases separate from all other kinds of tax treaty disputes. Recourse to MAP to…

Digital economy, Digital services tax, DST, United States

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Chiomenti)/ /Leave a comment

Trump wasted no time. Just over a month after the 20 January Memoranda, the President issued a new Memorandum on 21 February, this time setting his sights squarely on the digital sector. Presented as a measure to defend American companies and innovators against what is called “overseas extortion”, the Memorandum paves the way for the…

Customs and Excise, Direct taxation, EU law, Indirect taxation

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University)/ /Leave a comment

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

Corporate income tax, ESG

(Brazilian economist, accountant and lawyer. Master in Tax Law in Brazil and in the United States. )/ /Leave a comment

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)…

India, Luxembourg, Principal purpose test, Uncategorized

(KU Leuven)/ /Leave a comment

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…

MNEs, Pillar II, UTPR

( PwC Netherlands, Lazarski University and Singapore Management University) and (Assistant professor at Leiden University and tax advisor at De Brauw Blackstone Westbroek, Amsterdam. )/ /Leave a comment

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…

EU law, Global minimum tax, United States

(Reader in Tax Law, King’s College London )/ /Leave a comment

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…

Customs and Excise, Direct taxation, EU law, Indirect taxation

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University)/ /Leave a comment

 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…

Brazil, Financial services, Tax reform, VAT

(Fundação Getúlio Vargas) and (Loria Advogados)/ /Leave a comment

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,…

Uncategorized

(General Editor of Intertax)/ /Leave a comment

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…

EU, European Commission, G20, Global minimum tax, International Tax Law, OECD, United States

(Maastricht University)/ /Leave a comment

*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…

Uncategorized

(General Editor EC Tax Review and tax adviser at Ernst & Young Belastingadviseurs LLP)/ /Leave a comment

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…

Arm's Length, Company, Developing Countries, Direct taxation, Double Taxation, Finland, income tax, India, International Tax Law, MNE Profits, MNEs, OECD, OECD MC Convention, Permanent Establishments, South Africa, Tax Treaties, Transfer Pricing, UAE, UN Tax Convention, Uncategorized, United Kingdom, United Nations, United States

(Temple Tax Chambers; King’s College London)/ /1 Comment

“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…

Customs and Excise, Direct taxation, EU law, Indirect taxation

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University)/ /Leave a comment

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…