Please find below a selection of articles published this January 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 area of direct taxation and…

Highlights & Insights on European Taxation Please find below a selection of articles published this month 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…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Joachim Englisch, GloBE Rules and Tax Competition This article studies foreseeable effects that a relatively comprehensive implementation of the Pillar 2 GloBE international effective minimum tax would have on international tax competition for investment….

Highlights & Insights on European Taxation Please find below a selection of articles published this month (November 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…

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…

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…

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…

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…

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…

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…

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…

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…

In a judgment rendered on 5 October 2021 (case 2C_891/2020), the Swiss Federal Supreme Court upheld the decision by the Federal Administrative Court of 18 September 2020 (case A-7028/2018), which had found that the proceeds realized by a Swiss corporate VAT taxpayer from the resale of a position of its own stock (“treasury shares”) did…

Case law on thepurpose of transactions is starting to develop around the world. Is there a common pattern? Whether a financing structure was a “tax avoidance arrangement”  under  now repealed general anti-avoidance provisions of the New Zealand Income Tax Act 2004  was examined last month by the New Zealand Court of Appeal in Commissioner of…