…Pillar 2 UTRP (Under-Taxed Profits Rule) rule finally come into effect, this could potentially result in significant additional taxation for American companies. Increased Allocation of Tax Revenues to Market States:…
…under conditions comparable to those in a domestic market (Article 26 of Treaty on the Functioning of the European Union (TFEU)).[i] This has been an incentive for EU citizens to…
…Requires Tax Treaty Modification’, Kluwer International Tax Blog, January 12, 2022. [19] See https://news.bloombergtax.com/daily-tax-report/us-companies-move-behind-american-shield-to-delay-global-tax. [20] See, e.g., https://www.vietnam-briefing.com/news/draft-global-minimum-tax-support-fund-unveiled.html/, and see e.g., Martin A. Sullivan, ‘Will Singapore’s Refundable Investment Credit Trigger…
…person must either accept a lower profit margin or lower competitiveness than its competitors (Opinion AG, paragraph 63). In the AG’s Opinion, an undertaking competing with Company B and applying…
…incorporated company. The UK company was the parent company of a property investment group of UK resident companies that invested in immoveable property in the UK. The group was financed…
…tax law has not kept pace with these changes, with potential significant consequences for the functioning of the Internal Market. The aim of this article is to consider the compatibility…
…allocation of taxing rights between the source and residence states. This article posits that the concept of ‘digital nomad’ only pertains to the Global North, and it is completely alien…
…in BEFIT and Pillar Two: Harmony, Dissonance, or Off-Key? On 12 September 2023, the European Commission published the directive proposal ‘Business in Europe: Framework for Income Taxation’ (hereinafter ‘BEFIT Proposal’)….
…compatibility with EU law of the exception to interest deduction set forth in Article 10d of Chapter 24 of the Swedish law on income tax in the Lexel case, the…
…of computable assets to a Dedicated Branch for the purposes of its establishment, registration, and adherence to RIGI. To comply with the minimum investment amount (first 40% of the committed…
…Lamensch) (H&I 2024/87) INDIRECT TAXATION, CASE LAW – B2 Energy (C-676/22). VAT exemption of intra-community supplies. Status of taxable person. Court of Justice (comments by Kevin van Abswoude) (H&I…
…as loan terms, for instance, align with the commercially rational behavior expected between two independent entities. The Commentary on Article 9 of the OECD Model, for instance, specifically addresses an…
…of the Husky Energy case). Three tax resident companies in Barbados (Barbcos) owned a significant percentage of shares in Husky Energy, a Canadian tax resident and public company. In August…
…from the 1977 and 2003 versions of the OECD Commentary to Art. 10 and the 1986 OECD Conduit Companies Report to decode the meaning of the BO of dividends. The…
