By Jefferson VanderWolk Partner, Squire Patton Boggs[1] The GloBE Model Rules were issued in final form in December 2021. No public consultation was undertaken regarding any draft Model Rules, as there was a need for speed in light of the tight timeline for implementation of Pillar Two’s 15% global minimum tax that had been agreed…
Highlights & Insights on European Taxation Please find below a selection of articles published this month (October 2022) 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 the…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Brown & G. Jackson, Interpretation of Multi-Lateral Treaties: The Purposive Approach and Multiple Parties Through the Lens of the UK Courts In this article the authors consider how to interpret the multilateral provisions in…
Highlights & Insights on European Taxation Please find below a selection of articles published this month (September 2022) 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 the…
By María Amparo Grau Ruiz[1] Why taxation of carbon offset credits matters? A carbon offset is basically a removal or reduction in greenhouse gases (GHG) emissions, or an increase in carbon storage, that is used to compensate for emissions that occur elsewhere (i.e., another company which may be in another sector, area or even jurisdiction)[2]….
Highlights & Insights on European Taxation Please find below a selection of articles published this month (August 2022) 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 the…
On August 25, 2022, the Sixth Circuit Court of Appeals answered a fundamental question about advance pricing agreements (APAs): Is an APA a contract between the IRS and a taxpayer?[1] If it is a contract, is it subject to contract law? Circuit Judge John Nalbandian answered this question for the unanimous three-judge Appellate panel, opening…
Main features of the new extraordinary prepayment on account of Income Tax General Resolution 5248/22 (the Resolution), issued by the Argentine Tax Agency (AFIP), and gazetted on August 16, 2022, set forth an extraordinary (“one-time”) prepayment on account of Income Tax payable by corporate taxpayers contemplated in article 73 of the Income Tax law (ITL)[i]….
On Thursday, August 18, 2022, Chief Judge Kathleen Kerrigan of the U.S. Tax Court published her 75-page decision on the Medtronic and I.R.S. controversy (“Medtronic III”).[1] This decision resulted from a remand by the Eighth Circuit Court of Appeals (“Medtronic II”) of her original 144-page 2016 decision (“Medtronic I”).[2] The IRS and Medtronic had agreed…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Zhe Chen & Bart Peeters, A Study on the Protection of Taxpayer Rights in an Era of Enhanced Exchange of Information: How Can the Chinese Approach Be Improved? This study explores taxpayer protection under…
1. The IIR and the top-down approach It has become commonplace that the current OECD and Inclusive Framework (IF) proposals to address the tax challenges of the digital economy will represent a fundamental overhaul of the international tax system as we know it. As time passes, the international community has time to digest these possible…
As it currently stands, the legal and policy framework for non-profit organisations and foundations within the European Union differ – in some cases slightly, in others significantly. This regularly causes an inconsistent treatment of cross-border activities and generates high compliance and legal costs for NPO’s carrying out cross-border activities within the European Union. On February…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Lily Zechner, Understanding VAT in Three-Party, Platform-Based Business Models: Which Party Is Supplying Which Service? Three-party business models in which a platform operator intermediates between a supplier providing a service and a customer buying…
The transition toward a cashless society is at the heart of many public policy discussions. The move is driven by several factors, such as the spread of debit and credit cards, the development of mobile and instant payment technologies favoured by FinTech and digital platforms, as well as the effects of the pandemic and the…
