…elements can properly match with the computer language components of a smart contract, providing an easy-to-use and comprehensive solution for TP control. Then, as for the aspects of an APA…
There’s something about OECD’s Pillar One. For some years now, the world has been under the spell of a new system of taxation of companies that make profits in countries…
…arguments: first, that the Spanish Government consulted the VAT Committee before implementing the ‘imaginative formula’ described above, and second, that the EU Commission has never started an infringement procedure against…
…the economic nexus requirement could be hiring staff from a group payroll company or having a limited number of employees employed by a Dutch group company and hiring the rest…
…EU GAAR, as enshrined in Article 6 ATAD, by Poland in 2019. One of the main hypotheses is that the combination of Articles 6 and 3 ATAD is a dangerous…
…[9] https://eur-lex.europa.eu/legal-content/NL/TXT/HTML/?uri=CELEX:32016D2391&from=EN [10] https://ec.europa.eu/competition/state_aid/overview/index_en.html [11] http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:12008E107:EN:NOT [12] https://curia.europa.eu/jcms/upload/docs/application/pdf/2019-02/cp190017en.pdf [13] https://ec.europa.eu/commission/presscorner/detail/en/IP_16_2402 [14] https://www.ed.nl/default/brussel-gronddeal-tussen-gemeente-eindhoven-en-psv-was-geen-staatssteun-video~a6bfbc4d/?referrer=https%3A%2F%2Fwww.google.com%2F [15] https://www.questia.com/library/journal/1G1-352250347/spanish-football-clubs-tax-debt-awakes-storm [16] https://www.oxera.com/agenda/assessing-state-aid-in-the-beautiful-game/ [17] https://euobserver.com/news/122546 [18] https://footballperspectives.org/plan-relieve-spanish-football-club-tax-debts/ [19] https://euobserver.com/news/122546 [20] https://nl.wikipedia.org/wiki/Joaqu%C3%ADn_Almunia [21] http://www.cis.es/cis/export/sites/default/-Archivos/Marginales/2700_2719/2705/Es2705mar_A.pdf [22] https://www.dutchnews.nl/news/2020/07/coronavirus-eu-bailout-came-close-to-failure-says-rutte/ [23] https://www.taxjustice.net/2020/04/08/revealed-netherlands-blocking-eus-covid19-recovery-plan-has-cost-eu-countries-10bn-in-lost-corporate-tax-a-year/…
…in various disputes since has come to rule that the question has been settled in Azadi Bachao Andolan. In a subsequent ruling of Green Emirates Shipping[17], the Tribunal noted that…
…http://www.oecd.org/tax/beps/oecd-g20-inclusive-framework-on-beps-meeting-january-2021.htm (4) In this sense, it is worth mentioning that a Public Consultation on a digital levy was launched by the European Commission on January 18, 2021, https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12836-Digital-Levy/public-consultation See also,…
…the judgment – still is) whether the service should be considered as completed on the day when the works are de facto terminated or upon formal acceptance of the completed…
HMRC v Embiricos [2020] UKUT 370 (TC) reflects a common issue that arises in connection with tax investigations or audits of internationally mobile individuals. Mr Embiricos filed his tax returns…
…a disproportionate tax burden on companies that are hardly profitable or even loss-making such as start-ups. Such companies would still be liable to the DST, regardless of whether they make…
…approved through a written procedure completed on 18 December 2020. [11] European Commission, Proposal for a COUNCIL DIRECTIVE amending Directive 2011/16/EU on administrative cooperation in the field of taxation, COM(2020)…
…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…
