Dual VAT

CJEU, Double Taxation, DTA, Dual VAT, ECJ, Financial institutions, Financial services, Fixed establishment, Indirect taxation, International Tax Law, Pensions, Permanent Establishments, Physical presence, Place of Supply, Place of taxation, Tax Treaties, United Nations, VAT, VAT grouping

(Temple Tax Chambers; King’s College London)/ /Leave a comment
PVD article 44

Territorial connection (or its more fashionable name “nexus”) for tax purposes is expressed in a variety of ways in domestic and international legal instruments. Permanent establishment in article 5 of the Model treaties and “fixed base” in article 14 of the UN Model are central concepts in direct tax subject matter jurisdiction. Fixed establishment The…

Brazil, Consumption taxation, Dual VAT, Tax reform, VAT

(York University, Canada) and (Insper; Associação Brasileira de Direito Financeiro)/ /Leave a comment

Since the promulgation of its 1988 Constitution, Brazil has been trying to implement a national VAT. Over the past 30 years, the opposing interests of States and the Federal Government have caused at least three broad tax-reform proposals to fail in Congress. Moreover, several interest groups have also been opposed to changes. Such conflicts of…