…the interposition of a Luxembourg resident company to own the Canadian company, which itself in turn was owned by the US investors. The case was of considerable significance to both…
…Public Comments, Uber, p. 10; Public Comments, Amazon, p. 8; Public Comments, Nestle, p. 12; Public Comments, Skadden, p. 6; Public Comments, Digital Economy Group, p. 5; Public Comments, KPMG,…
…must comply with. In the near future, this complexity is going to increase, at least in the area of VAT. Next year, the E-commerce VAT Package will take effect, and…
…published in MNETax , “Spanish government approves digital services tax targeting large multinationals“ which can be found at https://mnetax.com/spain-targets-large-multinationals-with-new-digital-services-tax-37756 [2] https://ec.europa.eu/taxation_customs/sites/taxation/files/proposal_common_system_digital_services_tax_21032018_en.pdf [3] https://data.consilium.europa.eu/doc/document/ST-6873-2019-INIT/en/pdf [4] http://www.congreso.es/public_oficiales/L12/CONG/BOCG/A/BOCG-12-A-40-1.PDF [5] https://www.lamoncloa.gob.es/consejodeministros/Paginas/enlaces/180220enlace_impuestos_d.aspx [6] http://kluwertaxblog.com/2018/03/16/eu-digital-services-tax-populist-flawed-proposal/; https://www.copenhageneconomics.com/dyn/resources/Publication/publicationPDF/2/462/1539953034/181019-dst-report.pdf…
In my previous post, I had discussed the judgment delivered in the case of Elsevier Information Systems Gmbh v. Dy. Commissioner of Income Tax which discussed the liability of the…
…on other similarly directed comments I have recently made in replying to the OECD’s invitation for comments on the Two Pillars and GloBE proposals (published with the other public comment…
…PE attribution Such changes are likely to follow next year. TDS levy of 1% on E-commerce transactions Additionally, in order to widen and deepen the tax net for e-commerce giants,…
…subject matter. That said, generally, a common understanding of this concept within corporate income taxation would entail that (1) no taxes should be imposed unless actual taxpaying capacity related to…
It may well be said that George and Ira Gershwin’s simple and unforgettable line, “Let’s call the whole thing off!”, sums up the European Commission’s (“Commission”) view that the “wholly…
…reason why citizens are compelled to pay taxes in the first place is precisely the fact that they are directly benefiting from a government activity, while the own amount of…
…companies within the EU having the ATAD exit tax provision partially emptied the content of the freedom of establishment principle. Cihat Öner, Comparative Analysis of the General Anti-Abuse Rule of…
…it has clearly won that State aid case on principle: the Commission is competent to check autonomously whether cross-border intragroup transactions conform to conditions that would obtain in open competition…
…rules by circumventing the comparability analysis that is at the heart of the rules.” Similarly, in Glencore Investment Pty Ltd v Commissioner of Taxation of the Commonwealth of Australia [2019]…
…rules were also published for efficient compliance and enforcement of the law. While the CGST Act has received an enormous amount of support and success in India, there has been…
