The GloBE Model Rules have introduced the Qualified Domestic Minimum Top-Up Tax (QDMTT) into the ruleset of the international compromise on an effective minimum tax (“Pillar 2”). A QDMTT is defined as a domestic minimum tax that applies to local constituent entities of in-scope MNEs and produces outcomes that are consistent with the GloBE rules….
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Tarcísio Diniz Magalhães & Francesco De Lillo, The Return of Windfall Taxation Windfall taxes are not new to the world, but they have assumed a variety of shapes and formats under different names in…
The UN Tax Committee is currently considering revising the UN Model Double Taxation Convention between Developed and Developing Countries[1], particularly Article 8 (Alternative B), which relates to International Shipping and Air Transport. The proposal[2], which was released earlier this year, suggests abandoning the current fiscal framework – i.e., international air traffic income being exclusively taxed…
Highlights & Insights on European Taxation Please find below a selection of articles published in September 2023 in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV. The journal offers extensive information on all recent developments in European Taxation in…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Georg Kofler, Curia Locuta, Causa Finita: Some Further Conclusions from W AG The Court’s decision in W AG on the cross-border utilization of treaty-exempt foreign losses has not only turned its back on Lidl…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Tsilly Dagan, GLoBE: The Potential Costs of Cooperation This article argues that the fact that the 2021 global tax deal (focusing on Pillar 2) is cooperative is not in itself proof of the deal…
Summary Vietnam reportedly considers granting subsidies to large multinationals with direct investments in the country, to compensate them for the higher taxes they may have to face there following the country’s introduction of Pillar Two domestic minimum top-up taxation rules per 2024. The OECD warned Vietnamese government officials that if subsidies to multinationals were found…
“[A]ny State claiming a pioneer role in the development of new technologies bears special responsibility for striking the right balance in this regard” – The European Court of Human Rights in the S. and Marper v. the UK case (4 December 2008) [para. 112] 1 Introduction Fundamental taxpayers’ rights impose on regalian authorities the obligation to be…
“[I]n this world, with great power comes great responsibility!” – Uncle Ben advice to the young Peter Parker, the 1962 Amazing Fantasy #15, by Stan Lee 1 Introduction Explainable artificial intelligence (XAI) systems in tax law are needed to comply with principles of law such as legality, proportionality and non-discrimination. A sufficient degree of explainability…
It has been 60 years since publication of the OECD 1963 Draft Double Taxation Convention on Income and Capital. That model has provided the core and structure of all subsequent model double tax treaties published by the OECD, the UN and some states. During this period the number of bilateral tax treaties has grown exponentially….
Highlights & Insights on European Taxation Please find below a selection of articles published this month (August 2023) in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV. The journal offers extensive information on all recent developments in European Taxation in the…
Sustainability has become a global imperative in recent years, driven by the realization that societies are on the brink of potentially irreversible environmental, economic, and governance collapse. Given the central role of law in shaping commercial activity that impacts communities and the planet, it is crucial to analyse the question of how various legal frameworks…
Progressive Income Taxation, Inequality, SDG 10 Reduced Inequalities It is generally believed that a progressive personal income tax is an effective instrument for enhancing income redistribution and, hence, reducing income inequality, at least in the short run[1]. Often, international organization advise switching to progressive taxation of income as one of the world’s best practices to…
Highlights & Insights on European Taxation Please find below a selection of articles published this month (July 2023) in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV. The journal offers extensive information on all recent developments in European Taxation in the…
