(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…
We are happy to inform you that the latest issue of the journal is now available and includes, among others, the following contributions: An editorial, Taxes and Regulation, by Alice Pirlot and myself, critically analysing the role of regulatory taxes, with reference to the articles published in this special issue. Johanna Hey, Effectiveness of Regulatory…
We are happy to inform you that the issue 1, 2020, of the journal is now available and includes the following contributions: My editorial, on The OECD Unified Approach and the New International Tax System: A Half-Way Solution. A Guest Editorial by Maarten Floris de Wilde: On the OECD’s ‘Unified Approach’ as Frankenstein’s Monster and…
We are happy to inform you that the latest issue of the journal is now available. It is a special issue on transfer pricing in the digital economy. It combines academics and practitioners’ analysis on recent developments, so that the reader gets the broad picture on some of the most complex issues related to the…
I am delighted to inform you that the June-July 2019 double issue of Intertax has been published. It includes the editorial by Stef van Weeghel, Digitalization in a Broader Tax Perspective; double-blind peer-reviewed articles on corporate tax systems, the MLI, cross-border losses and EU law, liability in EU VAT, and taxation of cryptocurrencies. You may…
I am delighted to inform you that Intertax, May 2019 issue, has been published. There you may read a critical editorial by Yariv Brauner, on the recent OECD developments on Digital Economy and Taxes: “Developments on the Digital Economy Front: Progression or Regression?”. You may also find excellent double-blind peer-reviewed articles on different relevant international…
I am happy to inform you that issue 4, 2019, of the journal is available and includes, among others, the following contributions: My editorial, entitled “The Commission Proposal to Replace Unanimity for a Qualified Majority in the Tax Field”, focuses on the European Commission Communication to the European Parliament, the European Council and the Council,…
