International Tax Law, MAP, OECD

(Head of Tax Policy Center, University of Lausanne, Partner, DANON, Lausanne and Chairman of the Permanent Scientific Committee (PSC) of the International Fiscal Association (IFA))/ /Leave a comment

Introduction On 22 May we delivered an opening address on the current practical challenges of dispute prevention and resolution at the International Tax Dispute Day organized in Singapore by the Tax Policy Center of the University of Lausanne and the Singapore Tax Academy. While acknowledging the progress made since the adoption of BEPS Action 14…

Abuse of law, Anti-tax avoidance, ATAD, Beneficial ownership, BEPS, Canada, Company, Developing Countries, Directive, Double non-taxation, Double Taxation, Holding company, International Tax Law, MLI, OECD MC Convention, Principal purpose test, Tax Avoidance, Tax haven, Tax Treaties, Treaty shopping, Withholding Taxes

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

The Judicial Committee of the Privy Council (the highest appeal court for a number of Commonwealth countries) ruled  last month that payment rapid payment of dividends by a Trinidadian company  through a chain of intermediate holding companies as required by the ultimate parent company in Canada was not artificial or fictitious for purposes of Trinidad’s…

EC Tax Review, EU law

(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: Koen Lenaerts, The Role of the Court of Justice in Enhancing Tax Fairness in the EU This Guest Editorial takes stock of ongoing efforts to enhance tax fairness within the European Union (EU), a…

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

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

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

Intertax

(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: Antonio Lopo Martinez, Global Taxation’s Price: Quantifying Pillar Two Damages in IIA Disputes This article addresses the emerging conflicts between Pillar Two taxation rules and international investment agreements (IIAs) by focusing on developing methodologies…

Intertax

(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: Xiaorong Li, An Analysis on Expropriation Risks of Top-Up Tax under Pillar Two As Pillar Two moves closer to implementation, its potential clashes with international investment agreements (IIAs) are gaining attention. Among other possible…

Dispute resolution, International Investment Agreements, UN Tax Convention, United Nations

(Head of Tax Policy Center, University of Lausanne, Partner, DANON, Lausanne and Chairman of the Permanent Scientific Committee (PSC) of the International Fiscal Association (IFA)) and (Prof. Dr. Adolfo Martín Jiménez, University of Cádiz)/ /Leave a comment

Prof. Dr. Robert J. Danon, University of Lausanne /DANON /Prof. Dr. Adolfo Martín Jiménez, University of Cádiz/AMJ ITC On 24-27 March 2025, the United Nations Committee of Experts on International Cooperation in Tax Matters (“UN Tax Committee”), in its 30th session, approved the latest changes to a new clause to be introduced into art. 25…

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…