We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Tamir Shanan, Doron Narotzki & Noam Zamir, A Time to Institutionalize the International Tax Regime The paper proposes replacing the existing and outdated decentralized international tax system with a centralized tax authority that would…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Han Kogels, Will the Road to Carbon Neutrality Become Even More Bumpy Than Ever? The first-ever global stocktake of what has been achieved and what still must be achieved since the 2015 Paris Agreement…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Vladimir Starkov, The Need for Plan B: Comments As of mid-July 2024, the Multilateral Convention (MLC) on Amount A seems to have received a lacklustre response from the majority of stakeholders, despite the extensive…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Rita De La Feria, What Is Tax Fairness? In the last two decades, the term ‘fair taxation’ has become ubiquitous in the European public debate. From a political economy perspective this increased popularity…

Highlights & Insights on European Taxation Please find below a selection of articles published this month (July 2024) 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…

Ricardo García Antón* The rapid developments in international taxation in the aftermath of the latest financial crisis (2010s), i.e. the fight against tax evasion and tax avoidance, the Pillars’ work, should make us reflect on how tax law is formed and equipped to provide solutions to the current world challenges. This inquiry leads to finding…

On Friday, the U.S. Supreme Court issued its expected overruling of the Chevron doctrine, which has been relied upon in 70 past Supreme Court decisions and approximately 17,000 in the Appellate and District courts.[1] I was reminded of a discussion about Chevron’s deference at the ABA Tax Section Transfer Pricing committee meeting at the mid-year…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Eric C.C.M. Kemmeren, Contributions to EC Tax Review: ESG and More Whereas, a regular editorial deals with a substantive EU tax law topic, this editorial aims at creating more awareness by (potential) authors…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Adrianto Dwi Nugroho, Muhammad Atthuur Brotoatmodjo, Arvie Johan, Nabila Asysyifa Nur & Muhammad Hawin, Lead Tax Administration: A Deal Breaker? This article examines the introduction of the lead tax administration (LTA) in the…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Stijn Blaakman & Jasper Korving, The Tax Base in BEFIT and Pillar Two: Harmony, Dissonance, or Off-Key? On 12 September 2023, the European Commission published the directive proposal ‘Business in Europe: Framework for…

The Tax Court issued a nine to eight split decision of six opinions (three in favor and three dissenting) upholding the Service’s 1994 blocked income regulations. Yesterday, February 9, 2023, the Tax Court finally issued its ‘split’ decision regarding the 3M “blocked income” issue (formally, a decision regarding the validity of the Treasury Regulation regarding…

The Canadian Federal Court of Appeal has upheld the Tax Court of Canada decision in Canada v. Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 (CanLII).   The case is of some significance because the Canadian Revenue Agency (“CRA”) sought to apply the Canadian domestic general anti-avoidance rule (GAAR) in order to deny treaty relief. The…

Globally, countries are making a concerted effort to rein in the direct tax challenges posed by the digital economy. Some of this work is directly inspired by the recommendations set out by the OECD as part of its 15-point Action Plan to tackle base erosion and profit shifting. The Indian government, too, introduced two key…