Some OECD officials have reportedly noted that countries should consider changing or eliminating potentially duplicative anti-avoidance measures, such as CFC legislation when they implement the 15% global minimum tax rules (or the so-called GloBE rules proposed by the OECD).[1] This blog will overview the German approach, which seems in line with this view, and the…

Raise your hand if you have any certainty of when recharges of costs between a branch and its head office fall outside the scope of VAT. Some time ago, we would have been pretty confident to regard such intra-entity ‘services’[1] – i.e., transactions between a branch and its head office – as falling outside the scope…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Reuven Avi-Yonah, Do Intangibles Fit BEFIT? This article argues that the BEFIT formula should not include intangibles because they are subject to manipulation and their value is reflected by other factors in the existing…

Highlights & Insights on European Taxation Please find below a selection of articles published last month, June 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…

Mees Vergouwen[1] On 21 June 2023, the Netherlands and Belgium signed a new tax treaty.[2] Part of (the protocol to) this tax treaty is a subordination clause[3] that provides that “nothing in this treaty shall prevent the application (…) of Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Axel Cordewener, We Need to Know When Previous Case-Law Has Been ‘Overruled’! – A Plea for More Legal Certainty in EU Tax Law In its recent judgment inW AG the Court of Justice of…

DAC7 The Seventh EU Directive on Administrative Cooperation in the field of taxation (“DAC7”)[1] introduced new reporting obligations for Platform Operators. Although these reporting obligations entered into force as of 1 January 2023 already and the first reporting deadline is 31 January 2024, the concept of Platform is not always clear. Thus, determining whether software…

The International Maritime Organization (IMO) is currently considering the implementation of a basket of measures to decarbonize international shipping. These are to be in line with the climate mitigation targets included in the Initial IMO GHG Strategy — including reducing GHG emissions from shipping by at least 50 percent by 2050 over 2008 levels —…

The Contents of Highlights & Insights on European Taxation Highlights & Insights on European Taxation Please find below a selection of articles published last month (May 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…

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Jeroen Lammers & Błażej Kuźniacki, The EU Solidarity Contribution and a More Proportional Alternative: A Study Under EU and International Investment Law This paper reviews the EU Solidarity Contribution that was recently introduced by…

Highlights & Insights on European Taxation Please find below a selection of articles published in April 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…

Claudia Dias Soares[1] Key concepts: carbon accounting, capture, storage and removal, ‘Fit for 55 in 2030 package’, fiscal and monetary policy, social justice, environmental integrity Creative carbon accounting and techno-optimism On the 25th of April, the European Council adopted key pieces of legislation delivering on 2030 climate targets, following up on the legislative procedure to…

Climate change and the use of natural resources present us all with a major challenge. We all have our part in it and we can all contribute to ensure that we do not live at the expense of future generations. Various reports and goals were agreed upon internationally (e.g. Brundtland Report and Sustainable Development Goals)….

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Han Kogels, A Changing World Making the Road to Carbon Neutrality Even More Bumpy Since the Conference of the Parties (COP) in Glasgow in November 2021 (COP26) the world has changed dramatically. In February…