…2020, available at https://www.moneycontrol.com/news/economy/policy/budget-2020-contextualising-cravings-for-abolition-of-dividend-distribution-tax-4874911.html [9] This position has resulted into DDT being characterised as an amorphous non-descript tax. For illustration, see, Tarun Jain, Dividend Distribution Tax: A Rejoinder to 339…
…the OECD’s Global Anti-Base Erosion Proposal is to develop a coordinated set of rules to address ongoing risks from profit shifting and to curb international tax competition. Two important components…
…11, Indo-Dutch BIT. [17] See, Mukesh Butani & Tarun Jain, What next after the Vodafone tax arbitration? Available at https://www.fortuneindia.com/opinion/what-next-after-the-vodafone-tax-arbitration/104758 [18] Article 2.4(ii), India’s revised BIT Model. [19] Ibid. It…
…at hand have their headquarters in Switzerland. They belong to a group of companies under a Dutch parent. The companies supply military troops and civilian emergency forces in various crisis…
…Guidelines (OECD Publishing, Paris, 2017) [3] https://www.oecd.org/tax/exchange-of-tax-information/convention-on-mutual-administrative-assistance-in-tax-matters.htm [4] https://www.oecd.org/tax/exchange-of-tax-information/taxinformationexchangeagreementstieas.htm#:~:text=The%20purpose%20of%20this%20Agreement,to%20address%20harmful%20tax%20practices. [5] The Mexican Authorities have announced recently that they are considering to block apps/websites of companies non-compliant with domestic tax rules…
…New Zealand Limited [2020] NZCA 383 . Deutsche Bank provided a complex, multiparty, multijurisdictional financing structure for to French Groupe Danone SA for the acquisition of a New Zealand company…
The classification of transactions comprising several elements, features, and acts[1] is a complicated and prominent issue in the EU’s common system of VAT. It is also a popular topic for…
…“allow the Comptroller of GST to deny a GST-registered business’ input GST claim, if the business knew or should have known that his purchase was part of or connected with…
…He equated tax competition between states to competition between firms and concluded that it is welfare-enhancing, per analogiam to “invisible hand” of competition in private markets. Tiebout believes that “voting…
…so-called ‘Cockfield proposal’. Since the early 1980’s, the European Commission seems to have ignored why Europe had adopted VAT in 1967.[2] The Treaty of Rome (1957) had introduced a complex…
…missed the first one: http://kluwertaxblog.com/2020/09/14/legal-impediments-to-the-introduction-of-an-eu-wide-carbon-border-adjustment-mechanism/). Cartoons will be added as a feature to some articles published on the blog. We believe that this will be a very powerful addition. Rather…
…e-commerce VAT package[3]). The book follows the structure of the VAT Directive with additional topical chapters on immovable property, intra-Community transactions, importation and exportation of goods, and a newly included…
…based on a proposal from the EU Commission and after consulting the EU Parliament, the Economic and Social Committee and the Committee of the Regions. Tellingly, no progress has been…
…burden of proof in State Aid cases lies with the Commission. Since Apple allocated its residual value to two stateless companies, it was on the Commission to substantiate that the…
