We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Vladimir Starkov, The Need for Plan B: Comments As of mid-July 2024, the Multilateral Convention (MLC) on Amount A seems to have received a lacklustre response from the majority of stakeholders, despite the extensive…
One strategic response of countries to the Global Minimum Tax (the GloBE rules) would be restructuring their tax incentives. The top-up tax effectively nullifies any tax incentive that brings the effective tax rate below 15%. This would push countries to redesign tax incentives that would otherwise produce an effective tax rate below 15%. In a…
The Pillar 2 initiative (GloBE and QDMTT) has been seen as the end of using low effective corporate income tax rates (either by virtue of low nominal corporate income tax rates and/or through the use of tax incentives) as a means to attract foreign investors. Sacrifices made by the host country in terms of lower…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Rita De La Feria, What Is Tax Fairness? In the last two decades, the term ‘fair taxation’ has become ubiquitous in the European public debate. From a political economy perspective this increased popularity…
Coca-Cola announced that it would appeal to the Eleventh Circuit Court of Appeals, based in Atlanta, the Tax Court’s final entered decision of August 2, 2024, in favor of the IRS’ determination of $9 billion of transfer pricing adjustments and the validity of the IRS’ blocked income regulations.[1] The 240-page Coca-Cola 2020 Tax Court decision[2]…
Highlights & Insights on European Taxation Please find below a selection of articles published this month (July 2024) in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV. The journal offers extensive information on all recent developments in European Taxation in…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Till Valentin Meickmann, Taxing Powers of the European Union The European Union and its Member States are facing enormous financial challenges. To address them, the EU has not only incurred its own debt…
Reader in Tax Law, King’s College London (Autumn 2024) The past 30 June 2024 was anticipated to be a historic moment. Inclusive Framework’s (IF) countries, both developed and developing, were expected to publicly commit to a crucial element of the “global tax deal” by signing the Multilateral Convention (MLC) for the OECD Pillar One. Expectations…
Ricardo García Antón* The rapid developments in international taxation in the aftermath of the latest financial crisis (2010s), i.e. the fight against tax evasion and tax avoidance, the Pillars’ work, should make us reflect on how tax law is formed and equipped to provide solutions to the current world challenges. This inquiry leads to finding…
Highlights & Insights on European Taxation Please find below a selection of articles published this month (June 2024) in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV. The journal offers extensive information on all recent developments in European Taxation in…
On Friday, the U.S. Supreme Court issued its expected overruling of the Chevron doctrine, which has been relied upon in 70 past Supreme Court decisions and approximately 17,000 in the Appellate and District courts.[1] I was reminded of a discussion about Chevron’s deference at the ABA Tax Section Transfer Pricing committee meeting at the mid-year…
At the end of 2017, Congress passed a once-off Mandatory Repatriation Tax (the “MRT”) of 8 to 15.5 percent of the undistributed total accumulated income of American-controlled foreign corporations over the past thirty years (since 1987).[1] This accumulated income, if distributed, would be taxed in the hands of the American shareholders. However, because Congress cannot…
Introduction Throughout my professional life, I have worked with international tax law. Consequently, I have witnessed various trends and tendencies for more than a quarter of a century. The period during which I’ve been involved in tax law in my view represents a golden age for the discipline. Significant developments have occurred. During my student…
Incongruence between Taxation and Representation in the 21st Century from a European Union (EU) Perspective The phenomenon of increasing mobility of individual taxpayers is manifesting itself all over the world. Within the European Union (EU) territory, this has been facilitated primarily by EU legislation and jurisprudence serving the Union’s core agenda of enabling intra-EU movement…
