…limitations on it”, ‘International community strikes a ground-breaking tax deal for the digital age’, OECD, 8 October 2021, https://www.oecd.org/tax/international-community-strikes-a-ground-breaking-tax-deal-for-the-digital-age.htm. [10] See for a comparison, Maarten Wilde and Ciska Wisman, ‘OECD…
…a recent reform by the German legislator may have the potential to be somewhat of an exemption hereto. The transferal of funds in compliance with the legislative framework governing the…
…to interpret their domestic (tax) laws in compliance with the principles from the agreement, including comparably formulated fundamental freedoms. Anna Drywa, Taxpayer’s Right to Privacy? In the last decade,…
…decision in SK Telecom (Case C-593/19).[13]For a comment on SK Telecom (Case C-593/19), see G. Beretta, SK Telecom. Place of Supply – Effective Use and Enjoyment – Double Taxation, Non-Taxation…
…Committee’s Working Paper no. 1013 on 19 April 2021. Notably, Romania requested the VAT Committee clarification regarding the application of place of supply rules in the case of services consisting…
…Commissioners [2003] EWHC 2813 (Ch), Park J, in the English High Court, observed that the non-discrimination rules in art 24 are mostly prophylactic rather than aimed at specific provisions. Limited…
…paid out by Spanish entities to their EU parent companies controlled by non-EU shareholders. In these cases, the Court addresses the two essential issues: the burden of proof in the…
…the UN Sustainable Development Goals). For this purpose, she can be contacted at Alice.Pirlot@sbs.ox.ac.uk. Her full profile is available here: https://www.sbs.ox.ac.uk/about-us/people/alice-pirlot. The Kluwer Tax Blog Team now has expertise in…
…more than under model A. That is, starting from identical combined ETRs, the local government has stronger incentives to increase the combined ETR under Model B. Thus, competing in combined…
…its parent or holding company. Thus, the paper presents a tabular representation of taxation in the DDT regime and the shareholder regime and compares them. To present the complete scenario,…
…Services Taxes and other relevant similar measures with respect to all companies, and to commit not to introduce such measures in the future.”[11] The main advantage of implementing uniform rules…
…member countries of the G20/OECD Inclusive Framework (IF) have committed themselves to pursuing a ‘common approach’ on an international effective minimum tax regime. This political agreement implies that member countries…
…rather as a flow of funds to the company equivalent to a capital contribution made by a shareholder upon a capital increase. The company effectively raises its net assets or…
…the Council, the European Economic and Social Committee and the Committee of the Regions, A new Circular Economy Action Plan. For a cleaner and more competitive Europe, COM(2020) 98 final…
