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…

The first part of this two-piece article titled “Virtual Activities: EU VAT’s Effort to Recompose the Broken ‘Unity of Action, Time and Place’ – Part I” provided an overview of the new place of supply rules for services relating to virtual activities introduced in the VAT Directive by the compromise text for updates on VAT…

On 7 December 2021, government ministers from European Union (EU) countries gathering at the EU Council agreed on updates of the current rules governing value added tax (VAT) rates for goods and services. The new EU rules on VAT rates represent a long-awaited modernisation of the relevant provisions contained in Annex III to Directive 2006/112/CE…