…Cancún (Mexico) and Cape Town (South Africa), respectively.* The compatibility of the Undertaxed Profits Rule (UTPR) with tax treaties based on the OECD or the UN Model Tax Convention (MTC)…
…with this, ‘EU competitiveness is without doubt at stake. The shift towards competition outside corporate income taxes Pillar Two does not eliminate tax competition. In fact, it simply shifts it…
…Jan de Jonge) (H&I 2025/27) MISCELLANEOUS – A bolder, simpler, faster Union: the 2025 Commission work programme (comments by the Editorial Board) (H&I 2025/53) – Communication from the Commission on…
The authors would like to thank Bernard Appy, Secretary for Tax Reform at the Ministry of Finance (Brazil) for his comments and inputs. It is well established in the academic…
…treatment of debt without promoting greater diversification in the portfolio choice of financing sources for corporate Europe as European companies remain heavily reliant on bank lending compared to their American…
…the Organization for Economic Co-operation and Development (OECD), the G20 and the EU to play down the necessity of such changes to comply with international law. If the European…
…not treat all companies equally. Maybe the functioning of the common market is improved but this is not the case for all (SME) companies. Raymond Luja , The Apple…
…to the OECD Commentary to Article 7 introduced in 2008, following the report on attribution of profits to PE. In particular, paragraph 11 of the Commentary to Article 7 contends…
…– P, Commission v Ireland (C-465/20). Advance tax rulings for the Apple Group. State Aid. Court of Justice (comments by Leopoldo Parada) (H&I 2025/8) FREE ARTICLE – P, Commission…
…See https://www.oecd.org/en/about/news/announcements/2025/01/global-minimum-tax-release-of-compilation-of-qualified-legislation-and-information-filing-and-exchange-tools.html. [75] See https://www.ndfr.nl/zoeken?query=NTFR+2023%2F1587+ and https://www.ndfr.nl/zoeken?query=NTFR+2024%2F1799. [76] See https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/global-minimum-tax/multilateral-competent-authority-agreement-exchange-of-globe-information.pdf. [77] See https://law-store.wolterskluwer.com/s/product/european-tax-law-eight-edition/01t4R00000P3fVMQAZ?srsltid=AfmBOoq8CQwHrRGRtxXmpJ3hcKj7atyTh_8U5TkSvY2LcGMLPabaZee3, Chapter 22. [78] See https://www.ibfd.org/shop/journal/towards-2020s-compromise-international-business-taxation-reflections-emerging-new-tax. [79] See https://kluwertaxblog.com/2024/09/24/taxing-digital-whats-next/. [80] See https://www.ibfd.org/shop/book/taxing-digital-economy, Chapter 1. [81] See https://www.ibfd.org/shop/book/sharing-pie-taxing-multinationals-global-market and…
…and workers. This position should come as no surprise. It confirms what was already expressed by dozens of members of Congress in a letter to the Secretary General…
…for Mutual Agreement Procedure under Article 26(1) of the Treaty. The Canadian Competent Authorities considered that the US should give the credit but the US Competent Authorities declined to agree….
…as a commitment to ‘do the right thing’. CSR-companies voluntarily accept an ethical responsibility to society (and environment) which is captured in the voluntary obligation to go beyond (strict) compliance…
…CONTENTS INDIRECT TAXATION, CASE LAW – UP CAFFE (C-171/23). No VAT exemption for SME’s in case of abusive practice by forming a new company. Court of Justice (comments by…
