Carbon Border Adjustment Mechanism (CBAM) – What is it About?
…same price on carbon emissions, as would have been paid if these goods have been produced in the EU. The EU Commission presented a proposal for a new CBAM Regulation…
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The UTPR is Inconsistent with the Nexus Requirement of Tax Treaties
…collect its share of the MNE group’s global top-up tax liability from the locally resident group company, simply because it is part of the MNE group. Now let’s assume that…
The Contents of Highlights & Insights on European Taxation, Issue 10, 2022
…TAXATION, LEGISLATION – The Commission proposes emergency market intervention to reduce bills for Europeans (comments by the Editorial Board) (H&I 2022/297) – European Commission: Q&A document on an emergency intervention…
The Contents of Intertax, Volume 50, Issue 11, 2022
…in the area of foreign investments. Peter Denk, Tax Competition and the EU Anti-Money Laundering Regime Member States engage in tax competition to expand their tax bases thereby risking a…
The Contents of Highlights & Insights on European Taxation, Issue 9, 2022
…of cigarettes from Belarus into the territory of Lithuania. Court of Justice (comments by Diederik Bogaerts) (H&I 2022/249) (comments by Yassine El Bojaddaini) (H&I 2022/248) – Compendium of Customs Valuation…
Taxing carbon offset credits
…on International Cooperation in Tax Matters: report on the 24th session (virtual session, 4-7 and 11-12 April 2022) E_2022_45_Add.1–E_C.18_2022_2-EN More information is available at: https://www.un.org/development/desa/financing/sites/www.un.org.development.desa.financing/files/2022-03/CRP.9%20Environmental%20Taxation.pdf https://www.un.org/development/desa/financing/sites/www.un.org.development.desa.financing/files/2022-06/2208552S.pdf [accessed 10 September 2022]….
The Contents of Highlights & Insights on European Taxation Issue 8, 2022
…of Justice (comments by Natalia Șvidchi) (H&I 2022/212) STATE AID – UK and ITV v Commission (T-363/19 & T-456/19). UK Group Financing Exemption scheme not in line with EU State…
Heads I Win, Tails You Lose. Or is an APA a contract subject to contract law?
…Eaton Corp. v. Comm’r, 2015 U.S. Tax Ct. LEXIS 66, *10. [14] Eaton Corp. v. Comm’r, 2015 U.S. Tax Ct. LEXIS 66, *18-19. [15] Eaton Corp. & Subsidiaries v. Comm’r,…
Argentina: Taxation without representation or how to disguise a new tax under the form of an additional prepayment of Income Tax
…beyond its constitutional and legal competence. Relevant aspects of AFIP’s competence and the Income tax system concerning prepayments and withholdings on account of the final tax liability The rules governing…
Medtronic I, II, and III – Who won? The IRS or the Taxpayer?
…comparison received licenses for 1,800 of Medtronic US’s patents. The Tax Court compared that as of May 2004 approximately 9 percent of the patents licensed by Medtronic US to Puerto…
The Contents of Intertax, Volume 50, Issue 8-9, 2022
…in China. From a comparative study between Chinese law and European law in general (combining EU law and the ECHR as interpreted by the European Court of Justice (ECJ) and…
Who is the “taxpayer” for the IIR and why it does matter
…(UTPR). This answer presents many challenges related to its compatibility with the traditional understanding of tax jurisdiction and with the intent to make it compatible with DTCs. As posed, the…
A statute for European cross-border associations and non-profit organizations – A new dawn for European regulatory harmonization in the non-profit sector?
…to cross-border charitable donations to NPO’s, complexity and inconsistency of comparability procedures, as well as the fact, that Member States have taken limited action (policy neglect). From the perspective of…
The Contents of EC Tax Review, Volume 31, Issue 4, 2022
…of Justice (ECJ), taking into consideration the economic and commercial reality of each case and placing particular emphasis on the view of the average consumer. To contribute to a more…