As previously reported on this Blog the EU Anti-Tax Avoidance Package was presented on 28th January 2016. The package included: –          Recommendation on Tax Treaties –          Amended Directive on Mandatory Exchange of Information (CbC) –          External Strategy for Effective Taxation –          Anti-Tax-Avoidance Directive (ATAD) The overall policy objective of the package is: –          Effective taxation:…

1. The Tendency We live in a time where the media, politicians, NGOs and activists increasingly are preoccupied with international tax matters. A simultaneous preoccupation is observed among the OECD, G20, EU countries and most other developed countries alike. This has led to continuously increasing regulatory requirements and strengthened legislation towards companies. The tendency is…

When the EU Anti Tax Avoidance Package was launched by the European Commission, a Study on Structures of Aggressive Tax Planning and Indicators was released simultaneously as Taxation papers – Working paper N. 61- 2015, which is available: here. Reading the Study provides a good basis for understanding the reasoning behind the Anti Tax Avoidance…

Written by Associate Professor, PhD, Michael Tell, Department of Law, Copenhagen Business School and Technical Advisor, CORIT Advisory. Darwin’s theory of evolution states that complex creatures evolve from more simplistic ancestors, while natural selection ensures that only the fittest survive and the others become evolutionary “dead-ends”. The aim of this blog contribution is to address…

Written by Associate Professor, PhD Anders N. Laursen, Department of Law, Aarhus University and Technical Advisor to CORIT Advisory On June 4th 2015 the High Court of Eastern Denmark decided to refer a case to the European Court of Justice (ECJ) concerning the Danish mandatory group taxation regime.  Also in June 2015, the Commission issued…

The 2010 Green Paper from the EU Commission led to significant amendments to the EU Auditor regulation (see REGULATION (EU) No 537/2014 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 April 2014 on specific requirements regarding statutory audit of public-interest entities and repealing Commission Decision 2005/909/EC). One such amendment is a ban against…

There are a lot of opinions on multinationals and their tax practices. One conventional perception is that multinationals have a general tax advantage over their domestic competitors as their international operations allow for substantial tax management to minimize the corporate tax burden at group level. A number of tax policy projects are in process and…

It is well known that case law from the European Court of Justice (ECJ) imposes limitations on the application of anti-avoidance rules by Member States. Accordingly, it is of vital importance that recommendations made under the OECD project on base erosion on profit shifting (the BEPS project), are adaptable, where necessary, to enable Member States…

The taxation of MNEs is widely debated. This is even more so with respect to MNE’s tax planning arrangements. Increasingly, however, it seems that politicians and the media are not paying enough attention to facts in the debate. Recently we have witnessed examples in my home country of this tendency. These examples are the reason…

It is well known that the world’s economies have turned into a global economy during the last decades. Moreover, it is nowadays common knowledge – also outside the professional tax community – that states are fighting each other for tax revenue, while multinationals are trying to reduce their tax burden through tax planning that may…