Advance pricing agreement, Australia, OECD

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On 28 September 2022, the Organisation for Economic Cooperation and Development (OECD) published its Bilateral Advance Pricing Arrangement Manual (BAPAM).[1] The BAPAM aims to help streamline bilateral advance pricing arrangement (BAPA) programs by providing 29 best practice recommendations to resolve commonly experienced issues.[2] Advance pricing arrangements (APAs) are a prospective dispute resolution mechanism for cross-border…

DAC6, DEBRA, EC Tax Review, Excise duties

(General Editor EC Tax Review and tax adviser at Ernst & Young Belastingadviseurs LLP)/ /Leave a comment
EC Tax Review

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Eric C.C.M. Kemmeren, Taxing Interest in the Debtor State as an Alternative to DEBRA Basically, a company can be financed by debt or equity. The general national tax systems are that interest, the…

Pillar II

(Acquisition Manager, Wolters Kluwer, Legal & Regulatory, International Group)/ /Leave a comment

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…

Customs and Excise, Direct taxation, EU law, Indirect taxation

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University) and (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff)/ /Leave a comment

Please find below a selection of articles published this February 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 area of direct taxation and state…

BEPS, Competition, Double Taxation, Intertax, State Aid

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Intertax

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Leonie Fischer, Jessica M. Müller & Christoph Spengel, The Distorting Effects of Imputation Systems on Tax Competition in the EU The design of corporate income tax systems and thus the taxation of (cross-border)…

Directive, Spain, Use and enjoyment, VAT

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VAT

Article 59a of the VAT Directive (Council Directive 2006/112/EC of 28 November 2006 on the common system of value added tax) was implemented into the Spanish domestic legislation through Article 70(2) of the Spanish VAT Law (Law No. 37 of 28 December 1992 on value added tax). This article contains a particular place of supply rule,…

Digital services tax, DST, EU, EU law

(University of Amsterdam - Loyens & Loeff)/ /3 Comments

Introduction The growing uncertainties about Pillar One’s success, coupled with the recent EU Council’s mandate to the Commission to submit an EU legislative proposal in case Pillar One fails, have reignited the debate on whether Digital Service Taxes (DSTs) are a possible and suitable solution to address the challenges raised by the digitalization of the…

Uncategorized

(Texas A&M University Law)/ /Leave a comment

The Tax Court issued a nine to eight split decision of six opinions (three in favor and three dissenting) upholding the Service’s 1994 blocked income regulations. Yesterday, February 9, 2023, the Tax Court finally issued its ‘split’ decision regarding the 3M “blocked income” issue (formally, a decision regarding the validity of the Treasury Regulation regarding…

Customs and Excise, Direct taxation, EU law, Indirect taxation

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University) and (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff)/ /Leave a comment
European Taxation

Please find below a selection of articles published this January 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 area of direct taxation and…

Budget, India, Trusts and Estates

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In the ruling administration’s last full budget before India goes to the polls, India’s Finance Minister, Ms Sitharaman, laid out the government’s vision – “Making India a technology-driven and knowledge-based economy with strong public finances, and a robust financial sector.” She identified four transformative opportunities for India: (i) economic empowerment of Women (ii) upliftment of…

Energy, Transfer Pricing, Windfall tax

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Energy security and energy prices have become one of the biggest economic challenges for the world right after the global pandemic. Commodity prices for coal, oil and gas increased sharply in 2022.[1] The soaring prices have generated abnormally high profits in the energy sector. In response, in September 2022, the European Union (EU) has agreed…

Intertax, Pillar II

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We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Victoria Perry, Pillar 2, Tax Competition, and Low Income Sub-Saharan African Countries This article explores the implications of Pillar 2 of the G20/OECD Inclusive Framework Blueprint for global tax reform on tax incentives and…

EC Tax Review

(General Editor EC Tax Review and tax adviser at Ernst & Young Belastingadviseurs LLP)/ /Leave a comment

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Editorial: Pillar 2, Fiat, and the EU Unanimity Rule on Tax Matters Taxation is one of only a handful of policy areas within the EU where approval of new legislation is still dependent upon…

Cross-border rulings, DAC8, Exchange of Information, HNWI, Pandora papers

(Assistant Professor at the University of Amsterdam /Manager Tax at PwC Netherlands Tax Knowledge Centre.)/ /Leave a comment

[1] “Pandora [Papers, VD] illustrates again the importance of tax transparency. Commission to come in coming months with directives on shell companies, publication of effective tax rates and exchange of tax rulings for wealthy individuals”. This was the first reaction of the European Commission (EC) by Benjamin Angel (Director at the DG Taxation and Customs…