In Memoriam Frans Vanistendael
…Tax Review is only one of the many legacies that Frans has left to the tax community. Kluwer Law International and I personally cannot thank Frans enough for his contribution….
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Corporate income tax, Double Taxation, Finance, Financial institutions, Financial services, International Tax Law, Liability to tax, MLI, OECD, Permanent Establishments, POEM, Residence, Rule of law, Tax Treaties, United Kingdom, United Nations, United States
When is tax payable “in accordance with” a double tax treaty?
…which the United States tax is computed.” (emphasis added) A companion provision treats income that may be taxed in the United States in accordance with the Treaty, including specifically interest…
The Contents of Intertax, Volume 49, Issue 10, 2021
…addressed long existing questions that arose in the distant analogous past. The author shows that the quest to compensate the market/user jurisdiction, which is driving the postMLI digital economy taxation…
Effective Minimum Tax Implementation by the EU: Which Alternatives?
…[10] See https://www.gov.ie/en/speech/615f7-statement-by-minister-donohoe-on-decision-for-ireland-join-oecd-international-tax-agreement/; https://www.independent.co.uk/business/rise-in-corporate-tax-rate-is-right-decision-donohoe-b1934322.html (each last accessed 20 Oct. 2021). [11] For a detailed description and analysis, see Becker/Englisch, Implementing an International Effective Minimum Tax in the EU, 2021, https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3892160….
Poland and Hungary versus the European Commission: The Pot Calling the Kettle Black
…der Leyen – a completely unknown German whom nobody outside Germany had ever heard of, let alone played a part in electing – became the new President of the Commission….
European Court of Human Rights (ECtHR), Freedom of Expression, Tax Disclosure, Tax transparency, Whistleblowing
When the public interest of the disclosed information is no longer enough for activating the safeguards derived from Article 10 of the European Convention on Human Rights
…puts the focus on the position of economic vulnerability. [iv] Are covered by the PCbCR the multinational companies as well as the stand-alone companies with a total consolidated turnover of…
Common Interpretation – it’s Time to Make it Common
…Court Decision on Common Interpretation: Recently, the Delhi High Court ruled in favour of the appellant taxpayer resorting to the principle of common interpretation in Concentrix Services Netherlands B.V. v….
Global Experts debate Landmark Indian Ruling on Software Taxation
…it is entitled to disregard status of commentary. For the exact role of commentary, he referred to Paragraph 3 – a Commentary is directed towards tax administrations to follow to…
VAT and Public Radio and Television Activities. Solved Case?
…of two Member States (Bulgaria and Spain) and the European Commission. The five-judge chamber’s ruling provides some clarification on this complex debate, although it also leaves some issues open, essentially…
“Back to the future?” – Belgian Court rules that DEMPE concept cannot be applied retroactively
…General Court (Seventh Chamber, Extended Composition), Grand Duchy of Luxembourg vs. European Commission, 12 May 2021, T‑816/17 and T‑318/18, §§ 154-155. [7] Article 2 of the Belgian Civil Code. [8]…
A Pre-BEPS, long-expected Landmark Argentine Supreme Court Decision on DTA interpretation and Domestic GAAR Application in a treaty Setting
…a DTA structured after the Andean Model Treaty (AMT) and the interposition of a Chilean holding company (Platform Company) by an Argentine ultimate corporate shareholder. [1] In general terms, the…
Colombia puts in place a preferential international shipping tax regime
…domestic and foreign companies can apply Not applicable. The regime lacks transparency. The regime is completely open in terms of transparency. Not applicable. There is no effective exchange of information…
How is the CJEU construing the fund management VAT exemption in light of digitalisation and outsourcing? – Part 2
…businesses who are at a competitive disadvantage compared to US counterparts that have no similar cost. This makes us wonder why there is a VAT exemption for the management of…
Corporate income tax, Dispute resolution, Double Taxation, India, International Tax Law, OECD, Permanent Establishments, Physical presence, Place of taxation, Tax Treaties, United Kingdom, United States
Permanent Establishment: when is business carried on?
…210 (TC). This month the focus is on the permanent establishment issues. The case concerned a complex financing structure General Electric Company group. The taxpayer, The GE Financial Investments Ltd…