…the [subsidiary] to the [parent] company from the goods which the [parent] company sells and supplies in [the subsidiary’s Member State]. They are distinct supplies of services and goods which…
…the NFTs are domiciled. In the case of B2C supplies of services, this determination has always been a complicated task. Still, in this particular case, it is even more complex…
…Court of Justice (comments by Marilena Ene) (H&I 2022/137) – Suzlon Wind Energy Portugal (C-605/20). Supply of services. Warranty repair against debit note. Court of Justice (comments by Jasmin Kollmann)…
…and real tax competition while developing countries continue to engage in real tax competition – provided that their tax incentives meet certain criteria. Should a developing country not adhere to…
…according to the environmental impact and this is something the approved tax fails to comply with. It is evident that different types of plastic have different consequences (for example, compostable…
…should treat comparable cases. Finally, German Regional Fiscal Courts will use the Federal Fiscal Court’s decision as a factual precedent if the facts are sufficiently comparable. The Federal Fiscal Court…
…reservations are a common feature of multilateral treaties. Only few multilateral treaties prohibit their parties the possibility to make reservations. Although parties to the MLI can commit to differing extents…
…all countries and that domestic law may include provisions that make it unnecessary to combine both to prevent treaty shopping, the Final Report set forth a minimum standard of commitment,…
…Zone (MFZ) – created in the 60s to attract investment to the state of Amazonas by giving tax breaks to companies[6] – did not take kindly to it. Companies established…
…Reality or Wishful Thinking?, Kluwer International Tax Blog (10 February 2022), http://kluwertaxblog.com/2022/02/10/building-a-sustainability-driven-tax-environment-in-the-eu-area-reality-or-wishful-thinking/ (accessed 29 March 2022). [6] Communication from the Commission to the European Parliament and the Council on Tax…
…the international law) comparable to double taxation conventions (DTC) provisions, lower level courts were allowed to condition treaty benefits to the demonstration that the taxpayer had complied with those principles….
…issues around the interpretation of a tax treaty concluded in English and French, both languages being equally authentic. The complex facts are summarised at http://kluwertaxblog.com/2020/07/29/income-from-immoveable-property-article-6-and-royalty-streams/. The Canadian resident bank received…
…other indirect taxes with specific purposes to products already subject to harmonized excise duties, provided that such taxes comply with the EU rules applicable to excise duties or VAT concerning…
…and PwC Rotterdam. [2] OECD (2022), Tax Challenges Arising from the Digitalisation of the Economy – Commentary to the Global Antibase Erosion Model Rules (Pillar Two), OECD, Paris, https://www.oecd.org/tax/beps/tax-challenges-arising-from-thedigitalisation-of-the-economy-global-anti-base-erosion-model-rules-pillar-two-commentary.pdf (Commentary)….
