…the OECD’s Committee on Fiscal Affairs. To become a BEPS Associate in the Committee on Fiscal Affairs, non-OECD members have to commit, inter alia, to the comprehensive BEPS package and…
Introduction Let’s assume the following situation: ParCo is the parent company of a multinational group with its residence in Switzerland and engaged in the automotive business. It developed an innovative…
…for clearance by a new UK supervisor is still to be determined. The agreement brought us some further surprises that, combined, exclude UK taxation from effective state aid control for…
…Express, October 21, 2020, available at https://www.financialexpress.com/opinion/digital-taxes-if-multilateral-fails-look-for-bilateral-solutions/2110316/ [25] ASSOCHAM & BMR Legal, Equalisation Levy 2.0: India’s Digital Service Tax in the Making, (July 4, 2020), available at https://www.linkedin.com/feed/update/urn:li:activity:6686370831171403776/, pp. 21-28….
…concerning the purchases used simultaneously for activities of a commercial nature and activities of a non-exclusive commercial nature. The Bulgarian tax authorities consider that BNT provided both taxable supplies, namely…
…the answer to this question will depend on the rules (private law or public law) governing the company’s activity. However, in real life, companies controlled by mixed rules exist, both…
…lived in the UK, where he was treated as a UK “resident bot not domiciled” taxpayer. Mr. A held shares in several Swiss companies, from which he received substantial dividends,…
…tax competition. Administrative cooperation in combating VAT fraud and mutual assistance in recovering tax claims follows existing EU law instruments. What immediately caught my eye however, are general provisions and…
…this year 2020 behind with COVID-19 vaccines and economic recovery plans (the two shining eggs in the cartoon below) as new signs of hope, we cherish our commitment to improving…
…government owned entities, exchanges, commodities brokers, investment companies and advisers, any pooled investment vehicle, insurance companies and producers, retail foreign exchange dealers, and public accounting firms. Each reporting company shall…
On 15 July 2020, the European Commission (EU Commission) unveiled a Proposal for a Council Directive amending Directive 2011/16/EU on administrative cooperation in the field of taxation (the so-called ‘DAC…
…[16] Para 6.7 of the 2017 OECD Transfer Pricing Guidelines. [17] [2015] 64 taxmann.com 150 (Delhi)[11-12-2015] Maruti Suzuki India Ltd. vs. Commissioner of Income-tax, [2016] 65 taxmann.com 141 (Delhi)[23-12-2015] Bausch…
…12B of the 21st session is available at: https://www.un.org/development/desa/financing/sites/www.un.org.development.desa.financing/files/2020-10/CITCM%2021%20CRP.41_Digitalization%2010102020%20Final%20A.pdf (accessed Nov. 15, 2020). [2] OECD (2008), Building An Institutional Framework For Regulatory Impact Analysis, OECD Publishing, Paris, https://www.oecd.org/regreform/regulatory-policy/40984990.pdf (last visited…
…Aims and Tax Related Reforms On 23 July 2020, the European Commission launched public consultations on two tax related proposals, namely a revision of the Energy Taxation Directive and the…
