…to respect for communications with client (comments by Edwin Thomas) (H&I 2023/5) STATE AID – Tackling distortive foreign subsidies on the internal market. Council (comments by Raymond Luja) (H&I…
…The Distorting Effects of Imputation Systems on Tax Competition in the EU The design of corporate income tax systems and thus the taxation of (cross-border) dividends are encompassed within the…
…gave a certain comfort to taxpayers. However, as the author pointed out, this criterion has not remained static but evolved towards a broader application adding more complexities to the process….
…Digital Presence, COM(2018) 147 final (21 Mar. 2018); and European Commission, Proposal for a Council Directive on the Common System of a Digital Services Tax on Revenues Resulting from the…
…this regulation are not clear cut. [1] 3M v. Commissioner, 160 T.C. No. 3 (Feb. 9, 2023) addressing the validity of Treasury Regulation § 1.482-1(h)(2). [2] Amazon.com, Inc. v. Comm’r,…
…Bremen (C-431/21). Tax surcharge for non-compliance with obligation to keep documents on cross-border business transactions between related companies. Court of Justice (comments by Edwin Thomas) (H&I 2022/371) INDIRECT TAXATION,…
…companies – these have now been extended to notified non-banking financial companies (NBFCs). This is a welcome move – NBFCs are regulated when it comes to leverage. Audits The timeline…
Energy security and energy prices have become one of the biggest economic challenges for the world right after the global pandemic. Commodity prices for coal, oil and gas increased sharply…
…the acceptance of almost all common accounting standards under Pillar Two incentivizes generally accepted accounting principles (GAAP) competition between countries. The authors conclude that connecting Pillar Two to financial statements…
[1] “Pandora [Papers, VD] illustrates again the importance of tax transparency. Commission to come in coming months with directives on shell companies, publication of effective tax rates and exchange of…
…effect is short-term (revenue) gains with long-term (economic) pain. In fact this generates a country-risk that is substantially higher compared to other developed economies. This is chiefly because in other…
…Secondly, these providers report the collected information to the competent tax authority of the Member State where they are based (for EU providers) or the competent authority of the Member…
…agreement between the EU and Moldova enters into force on 1 November 2022 (comments by Piet Jan de Jonge) (H&I 2022/338) – Publication of a new Combined Nomenclature (comments by…
…Domaines and de la TVA (C-288/20). Comparison of company directors’ services under UAE and EU VAT From the comparative analysis carried out above, it can be concluded that company…
