Where is a person “established”?
…Branches of the companies were registered with Companies House as branches of overseas companies for company law purposes. Employees were seconded to staff the UK branches and undertook roles such…
…Branches of the companies were registered with Companies House as branches of overseas companies for company law purposes. Employees were seconded to staff the UK branches and undertook roles such…
…on May 23, 2007, in Brussels. Available online (only in French) at : <http://www.droit-afrique.com/upload/doc/rdc/RDC-Convention-fiscale-Belgique.pdf> (assessed on February 2, 2022). [14] 2017 OECD Commentary, Art. 5, para. 54. [15] 2017 OECD…
…conflicting unilateral systems of taxation. Disadvantages, instead, particularly for LATAM countries, focus on (i) the excessive complexity for both taxpayers and tax administration, coming from complex, formulary rules on the…
…and precision of the execution of tax law must sometimes be compromised for the sake of effectiveness in preventing tax frauds, this compromise must be well justified, and the justification…
…negatively affected stock prices due to investors’ concerns about: reputational backlash linked to the perception that the company has applied not-so-fair tax policies; competitive disadvantages from competitors accessing sensitive company…
…emissions to net zero by 2040. The Austrian Ecological Tax Reform Act contains a variety of climate and compensatory measures for citizens and companies. A central part of the tax…
…base. [1] https://www.taxcomplexity.org [2] https://www.hindustantimes.com/business/govt-to-refund-rs-7-900-crore-retro-tax-to-cairn-company-to-withdraw-cases-101637235754715.html [3] India’s SEZ regime which included a host of tax & regulatory relaxations for businesses operating in areas designated as SEZs saw tremendous success in…
…and the Proposed Carbon Adjustment Mechanism, Ibidem, http://kluwertaxblog.com/2020/08/18/the-eu-green-deal-and-the-proposed-carbon-adjustment-mechanism/, 18 August 2020. [6] European Commission, A new Circular Economy Action Plan – For a cleaner and more competitive Europe, COM (2020)…
…their different views only through political or strategic compromises. One key point was the fiscal treatment of commuters, concerning some Italian regions of the North and the three mentioned neighbouring…
…in the Engie-case, according to which the non-application of the Luxembourg General Anti-Abuse Rule (‘GAAR’) is considered state-aid. Engie had set up a complex intra-group financing structure between Engie-companies located…
…Commission, Corporate sustainability reporting, https://ec.europa.eu/info/business-economy-euro/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en, access: 20.01.2022. [5]Resolution adopted by the General Assembly on 25 September 2015, Transforming our world: the 2030 Agenda for Sustainable Development, https://www.un.org/ga/search/view_doc.asp?symbol=A/RES/70/1&Lang=E , access 20.01.2022….
…matters – are presently required to devote their expertise to the taxation of this new reality. While professional literature – at least in Germany – has already found a common…
…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…