Back in April this year, my contribution on the Panama Papers scandal started by saying that: “Massive leaks of information on offshore activity like the Panama Papers illustrate the need for enhanced global tax cooperation with an improved and deeper inter-jurisdictional information sharing scheme.”[1] It is not now my intention to follow the subsequent episodes…

On June 27, 2016 the EU Commission published the long awaited Starbucks State Aid decision (see here).  The EU Commission’s decision challenges the outcome of the Advanced Pricing Agreement (APA) between the Netherlands Tax Authority (Tax Authority) and Starbucks Manufacturing BV (SMBV), a wholly owned and controlled coffee roasting operation. Below is the Part I…

Probably without noticing it, Colombia did not take into account that signing the recent DTT with France would allow some treaty-covered taxpayers to claim Most-Favoured-Nation (MFN) protection. Some of Colombia’s DTTs, as the ones signed with Spain, Chile, Switzerland, Portugal and Mexico, include Most-Favoured-Nation clauses with respect to royalties. In this sense, it is important…

1. The Tendency We live in a time where the media, politicians, NGOs and activists increasingly are preoccupied with international tax matters. A simultaneous preoccupation is observed among the OECD, G20, EU countries and most other developed countries alike. This has led to continuously increasing regulatory requirements and strengthened legislation towards companies. The tendency is…

Volume 25 (2016) issue 2 contains: EDITORIAL: MICHAL AUJEAN, ‘Some Twenty-Seven Years after…’ Abstract: When I started writing this editorial a question quickly came to my mind: what have I been doing all these years that I devoted to taxation and more specifically to European tax policy? Then I thought it was time to say…