We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Andrés Báez Moreno & Yariv Brauner, Pillar One and Alchemy: What Can We Learn from past Mistakes Pillar One’s Amount A has failed miserably. However, the paper attempts to enumerate the many political and…
Highlights & Insights on European Taxation Please find below a selection of articles published this November 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…
Welcome to the latest tax podcast in the International Law Talk series. During a series of podcasts, Wolters Kluwer will bring you the latest news and industry insights from thought leaders and experts in the field of International Arbitration, IP Law, International Tax Law and Competition Law. Here at Kluwer International Tax Blog, we will…
What is CBAM? Have you heard of CBAM? No? Well, depending on your line of business it may now be time to read up on it. The major EU framework was established by an EU Regulation adopted by EU co-legislators on 16 May 2023 (OJ L 130/52 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R0956; the CBAM Regulation). It lays down obligations…
Introduction Two and a half years ago, the Kluwer International Tax Blog published a great contribution from Pawel Mikula titled “Are the Court of Justice of the European Union (CJEU)’s judgments on VAT too hard to understand?”. One could be forgiven for thinking that the recent judgment Deco Proteste – Editores (C‑505/22) was the CJEU’s…
Highlights & Insights on European Taxation Please find below a selection of articles published in October 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 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…
