When is a tax treaty not a treaty?
…consent at the international plane. Kenya, like many Commonwealth countries has legislation of a general nature to give effect to treaties under domestic law. In Kenya this is governed by…
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A New Addition to the Editorial Team
…Pricing, Tax Treaty and EU Tax Law matters. If you would like to get in touch with him and make a potential contribution, kindly send him an email on: klitaxblog@gmail.com…
India needs to rethink attitude towards corporate tax avoidance
…stern penalty regime must be introduced in the Income Tax Act to deter companies from attempting to bypass the GAAR. In case of repeated violations, companies should be subject to…
Why a Minimum Effective Tax Rate is Urgently Needed
…practices, has increased tax competition for real economic activities. A minimum tax puts a floor in such competition. For some readers, this will ring alarm bells. Competition is good, and…
The Contents of EC Tax Review, Volume 28, Issue 1, 2019
…saga in the continuous political battle between the Member States and the European Commission about the limits of article 107 TFEU within the complex multi-level tax governance system of the…
Foreseeing the Impact of X GmbH (Case C-135/17), III: The Importance of the Genuine Exchange of Tax Information with Third Countries
…on 26 February 2019, the CJEU for the first time examined a compatibility of CFC rules with the EU primary law to the extent of their application to companies established…
The Interplay between Beneficial Ownership and Abuse in the Danish Cases on Dividends
…relevant criteria for the purposes of beneficial ownership, but the former analysis is more complex, has a different nature and should include reviewing the substance of the holding company and…
The Contents of Intertax, Volume 47, Issue 3, 2019
…at the EU Level: Why Trust Matters”, where the author discusses the lack of trust between EU tax administrations, the very slow progress in the negotiations concerning the common consolidated…
Foreseeing the Impact of X GmbH (Case C-135/17), II: A Reasonable Understanding of the PPT Standard under OECD Guidelines and US Case Law
…asset to generate growth and innovation, attract investments and foster the competitiveness of its companies in globalised markets”,[9]Communication from the Commission to the European parliament, the European Council, the Council,…
What do the Current OECD Proposals say about Global Tax Governance?
…including developing countries. At the time of writing (March 2019), 129 countries are participating in the BEPS Inclusive Framework and have committed to implemented 4 Minimum Standards which deal with…
Foreseeing the Impact of X GmbH (Case C-135/17), I: Understanding the PPT Standard under CJEU Case Law
…on 26 February 2019, the CJEU for the first time examined a compatibility of CFC rules with the EU primary law to the extent of their application to companies established…
Fictional Interest Payments and Abuse of European Tax Law: New State Aid Challenges?
…closely links commercial and tax accounts are likely to have a similar response. A quite straightforward explanation: suppose that one company provides an interest-free loan to another company, because they…
Abuse of law, Beneficial ownership, Double Taxation, EU/EEA, International Tax Law, OECD, Substance, Tax Avoidance, Tax Treaties
Three Observations on the Danish Beneficial Ownership Cases
…a common system of taxation applicable to interest and royalty payments made between associated companies of different Member States, COM(2003)841 final. and again in 2011 to include a more stringent…
The Contents of Intertax, Volume 47, Issue 2, 2019
…services tax (DST) on revenues resulting from the provision of certain digital activities, specifically in light of its compatibility with the guaranteed free movement of goods and services. The compatibility…