Direct taxation

Abuse of law, Anti-tax avoidance, Beneficial ownership, BEPS, Direct taxation, Financial transactions, Fund management, Ireland, MLI, OECD, Principal purpose test, Tax haven, Tax Treaties, Treaty shopping, United Kingdom, Withholding Taxes

(Temple Tax Chambers; King’s College London)/ /4 Comments
article 3(2), burden of proof, OECD Commetary, treaty interpretation, UN Commentary

Even before introduction of the BEPS PPT, the UK has had purpose-based provisions in various forms, designed to limit access to treaty benefits in its double tax treaties since the 1960’s. Its standard formulation first appeared in 1992.  Surprisingly, the first case in which the meaning and application of this wording in a tax treaty…

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 (October 2022) 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…

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 (September 2022) 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…

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 (August 2022) 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…

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 (July 2022) 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…

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 (June 2022) 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…

CJEU, Direct taxation, ECJ, EU, Germany, Indirect taxation, International Tax Law, Non-established taxpayers, OECD, Permanent Establishments, Physical presence, Place of taxation, Tax Treaties, United Nations, VAT

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

The very recent CJEU judgement in Berlin Chemie A. Menarini v Administraţia Fiscală pentru Contribuabili Mijlocii Bucureşti (Case C-333/20) ECLI:EU:C:2022:291, admirably examined by Giorgio Beretta last week considered the circumstances in which a subsidiary might be a VAT fixed establishment (FE) of its parent company or another affiliate. A Romanian company supplied advertising, marketing and…

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 (May 2022) 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…