We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Nevia Čičin-Šain & Joachim Englisch, DAC 7: An Entire New Framework for Joint Audits in the EU: How Do the Taxpayers Fare? Joint audits have the potential to facilitate tax collection and at…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Polyvios Nikolaou, Mandatory Binding Arbitration: Avoiding Stalemates Over the Tax Chessboard The resolution of tax treaty disputes under the Mutual Agreement Procedure (MAP) mechanism is inherently problematic. This article examines how the introduction…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Edoardo Traversa & Benoît Timmermans, Value-Added Tax (VAT) and Sustainability in the European Union: A Radical Proposal Design Issues, Legal Aspects, and Policy Alternatives This article aims to examine how the implementation of…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Svetislav V. Kostić, A Plea for a Workforce Presence PE Concept in a Post-Covid Digitalized World This paper begins with the recapitulation of the generally accepted view that the key problem with the…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Aleksandra Tychmańska, The OECD as the Future International Tax Organization: An Inevitable Course of Events? Over the years, the increasing process of tax law internationalization may be observed due to which tax cooperation…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Robert Danon, Daniel Gutmann, Margriet Lukkien, Guglielmo Maisto, Adolfo Martín Jiménez & Benjamin Malek, The Prohibition of Abuse of Rights After the ECJ Danish Cases Since they were delivered in February 2019 the…
(Forthcoming: Intertax, vol. 49, 2021, issue 8/9) Like it or not, the Covid-19 pandemic has been changing our way of life. Among others, large-scale lockdowns drive us to work from home and to rely heavily on videoconferencing and online-shopping. Thus, the arguably already digitalized life has been further digitalized! In the fiscal circle, the tax…
(Forthcoming: Intertax, vol. 49, 2021, issue 6/7) The Spanish digital services tax (hereinafter DST)[1] came into force 16 January 2021 replicating the European draft directive except for some minor deviations. In essence, it applies a 3% tax on the revenues obtained by taxpayers as a result of the supply of certain digital services to users…
Analysis of the ECJ judgments, reading by national courts, and impact on tax treaty practice Authors: Robert Danon,[1] Daniel Gutmann,[2] Margriet Lukkien,[3] Guglielmo Maisto,[4] Adolfo Martín Jiménez,[5] Benjamin Malek[6] (Forthcoming: Intertax, vol. 49, 2021, issue 6/7) Since they were delivered in 2019, the judgments of the ECJ in the Danish cases have been widely…
Articles 3 and 6 ATAD: a dangerous EU legislative mix In the forthcoming issue of Intertax, I make an in-depth analysis of the issues concerning the partial implementation of the EU GAAR, as enshrined in Article 6 ATAD, by Poland in 2019. One of the main hypotheses is that the combination of Articles 6 and…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Carla De Pietro, Beneficial Ownership, Tax Abuse and Legal Pluralism: An Analysis in Light of the CJEU’s Judgment Concerning the Danish Cases on Interest The complex interconnections characterizing the relationship between the international…
In October 2020, the OECD Secretariat published the ‘Report on Pillar One Blueprint‘ approved by the Inclusive Framework on BEPS as a result of the work on the tax challenges arising from digitisation. The Unified Approach (UA), which is the basis of the Blueprint, is intended to complement the existing system of corporate income taxation….
Since the OECD introduced its Global Anti-Base Erosion Proposal (GLoBE) in early 2019 as the second pillar of the ongoing search for a solution to the tax challenges of the Digitalisation of the economy, the goal of GloBE seems to be moving. On the one hand, already the name suggests that the proposal for a…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Qiang Cai, Luca Cerioni & Xiaorong (Sharron) Li, New Taxing Right in the Unified Approach: Old Wine in a New Bottle The OECD’s ‘Unified Approach’ (UA) features new taxing rights allocated to market…
