Airlines, Developing Countries, OECD, Shipping, United Nations

, (Tax Policy Center of the University of Lausanne, Switzerland)/ /Leave a comment

What is the current Tax Framework under the UN Model for Taxation of International Shipping and Airline-related income? The current version of the United Nations Model Double Taxation Convention between Developed and Developing Countries (“UN Model 2021”)[1] offers two alternatives under Article 8. Alternative A aligns with the OECD Model Tax Convention on Income and…

New editor

(Tax Policy Center of the University of Lausanne, Switzerland)/ /1 Comment

We are proud to announce that Dr Alice Pirlot has joined the Kluwer International Tax Blog’s team as an editor, responsible for the new section of the blog dedicated to Environmental Taxation. Dr Pirlot, who defended her doctoral thesis at the University of Louvain in 2016, is currently a Research Fellow in Law at the…

CbCR, Europe, MNEs

(Tax Policy Center of the University of Lausanne, Switzerland) and (Assistant Manager at Deloitte Luxembourg)/ /Leave a comment

The vexed question of whether country-by-country reports (CBCR) on multinational companies’ tax affairs should be made public[1] has been a recurrent topic in the tax debates for years. In Europe several attempts were made along the year to have public CbCR without success. Furthermore, the approach adopted by European countries with reference to public CbCR…

Effective Tax Rate, GILTI, IIR, OECD, Pillar II, United States

(Tax Policy Center of the University of Lausanne, Switzerland)/ /Leave a comment

Welcome to the second tax post in the series of International Law Talk. During a series of podcasts, Wolters Kluwer will bring you the latest news and industry insights from thought leaders and experts in the field of International Arbitration, IP Law, International Tax Law and Competition Law. Here at Kluwer Tax Blog, we will…

ADS, Digital services tax, OECD, Pillar I, Transfer Pricing, United Nations

(Tax Policy Center of the University of Lausanne, Switzerland) and (University of Lausanne)/ /Leave a comment

1. Background During the 21st Session of the UN Committee of Experts on International Cooperation in Tax Matters, the relevant members decided to include a new draft – Art. 12B on Automated Digital Services (ADS) as well as its Commentary – in the UN Model.[1] Concerning the agenda of the proposal, the Committee of Experts…

cartoon, Kluwer podcast, NewYear

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University) and (Tax Policy Center of the University of Lausanne, Switzerland)/ /Leave a comment

As this year 2020 is withering and will soon be gone, it is an understatement that we all will find it hard to not look at the past year with regret. Almost since its first inception days, this year 2020 has trapped all of us in a spiral of pain and dispensed a great dose…

Digital economy, Kluwer podcast, MNE Profits, OECD, Pillar I

(Tax Policy Center of the University of Lausanne, Switzerland)/ /Leave a comment

Welcome to the first post in the series of International Law Talk. During a series of podcasts, Wolters Kluwer will bring you the latest news and industry insights from thought leaders and experts in the field of International Arbitration, IP Law, International Tax Law and Competition Law. Here at Kluwer Tax Blog, we will highlight…

BEPS, OECD, Pillar I

(Tax Policy Center of the University of Lausanne, Switzerland) and (University of Lausanne, Switzerland; CEDIDAC)/ /Leave a comment

Purpose of the blog This blog raises the question as to whether the Pillar I Amount A proposal is consistent with the value creation standard? Naturally, as a start, the question arises as to what the value creation standard is. Value creation standard Although the meaning of value creation, as used in the BEPS project,…

BEPS, Digitalization, MNEs, OECD, Pillar II

, (Tax Policy Center of the University of Lausanne, Switzerland)/ /Leave a comment

1. Introduction The Pillar Two Report[1] (the “Report”) which contains the Global Minimal Tax (the “GloBE tax”) proposal has recently been on the top of discussions both in the academic and practice world. While the proposals objective is debatable[2], the blueprint contains dozens of new rules, exceptions and mechanisms which may possibly complicate life not…

BEPS, Digitalization, MNEs, OECD, Pillar II, Tax competition

, (Tax Policy Center of the University of Lausanne, Switzerland)/ /1 Comment

1. Introduction The ability to stimulate economic activity and to attract foreign capital and investments through national tax policies has been known for many centuries. It was in the middle of the eighteenth century that the Russian Empress – Catherine the Great – granted to “[…] Foreigners that have settled themselves in Russia to erect…

Indirect taxation, VAT

(Tax Policy Center of the University of Lausanne, Switzerland)/ /Leave a comment

We are glad to announce that Dr Giorgio Beretta has joined the Kluwer International Tax Blog’s team as an editor, responsible for the new section of the blog dedicated to VAT/GST and indirect taxation. Dr Beretta holds a PhD in Tax Law from LIUC University (Milan, Italy), where he defended his doctoral thesis on “European…

BEPS, Digitalization, OECD, Pillar II, Tax competition

, (Tax Policy Center of the University of Lausanne, Switzerland)/ /Leave a comment

Purpose of the blog The purpose of the blog, which is slightly futuristic, is to discuss whether countries will still compete with one another to attract activities in their jurisdiction post-Pillar II implementation. State sovereignty and Tax Competition A sine qua non condition for the existence of international tax competition is the opportunity to transfer capital…

Digital platforms, Employment, Taxpayer classification

(Tax Policy Center of the University of Lausanne) and (Tax Policy Center of the University of Lausanne, Switzerland)/ /3 Comments

The purpose of this short contribution is to shed some light on the discussion regarding an Uber drivers’ qualification – whether they should be considered employees or independent contractors. If Uber is considered as an employer and the driver as an employee, then the Company will be responsible for certain matters. For instance, depending on…

Digitalization, OECD, Pillar I

(Tax Policy Center of the University of Lausanne, Switzerland)/ /Leave a comment

1. Purpose of the blog This contribution is a follow up to the previous contribution of the author. The objective is to address the tentative impact of the Pillar I debate on decentralized MNE business models in light of the “ongoing work” of the OECD with respect to the digitalization of the economy[1]. The reader…