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…
BEPS’ input to a fascinating discussion Taxation is the unrivaled field of law where public interest (attending state goals towards the population’s needs as a whole), in one hand, and private wealth protection, in the other, most apparently collide;[1] and the reason for that is quite simple: Public needs are financed out of private wealth…
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…
