DAC7 The Seventh EU Directive on Administrative Cooperation in the field of taxation (“DAC7”)[1] introduced new reporting obligations for Platform Operators. Although these reporting obligations entered into force as of 1 January 2023 already and the first reporting deadline is 31 January 2024, the concept of Platform is not always clear. Thus, determining whether software…
1. Background In the article Is the Multilateral Instrument (MLI) Really Multilateral? published in the book A Multilateral Convention for Tax – From Theory to Implementation of the Wolters Kluwer Series on International Taxation, edited by Sergio André Roche and Allison Christians,[1] I analyze the nature of the MLI, a topic that has raised discussions…
Introduction On 8th October 2021, 136 jurisdictions reached an historic agreement to reform the international tax system and, in the words of the OECD, bring it into the 21st century.[1] The so-called two-pillar solution was presented to the G-20 Finance Ministers and the G-20 Leaders, who endorsed it. Thus, the future work of the OECD…
