Fit for 55…or 57?
…“unavoidable”, acknowledging carbon removal as an important part of a comprehensive strategy to combat climate change. This increased focus on the use of CCS and carbon dioxide removal (CDR) methods…
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What’s ESG Got to Do with Transfer Pricing?
…are identified in jurisdiction B as possible comparables. The two companies differ only in their compliance with environmental standards. One company complies with environmental standards in a similar way as…
Arm's Length, Beneficial ownership, Carbon neutrality, CJEU, Digital platforms, EC Tax Review, EU VAT, VAT
The Contents of EC Tax Review, Volume 32, Issue 03, 2023
…length principle is only applied in a cross-border context, thereby impeding the free and competitive allocation of resources within the EU internal market and favouring domestic transactions. The second issue…
CIT in the UAE: The PE Clause for Individuals
…Shipping Business. g) Holding Company Business. h) Intellectual Property Business. i) Distribution and Service Centre Business. [20] See Paragraphs 18 and 19 of OECD MC Commentary on Article 5. Concerning…
CIT in the UAE: The PE Clause for Companies
…their bilateral convention’. The UN MC Commentary on Article 5 merely reproduced these statements from the OECD MC Commentary on Article 5. [10] Notably, one may consider that since UAE…
The Contents of Intertax, Volume 51, Issue 05, 2023
…Report on Double Taxation (1923) (League of Nations, Economic and Financial Commission, Report on Double Taxation Submitted to the Financial Committee by Professors Bruins, Einaudi, Seligman and Sir Josiah Stamp,…
The Contents of Highlights & Insights on European Taxation, Issue 3, 2023
…ethyl alcohol. Court of Justice (Summary comment by Giorgio Emanuele Degani) (H&I 2023/60) – Exchange of information on movements of excise goods between Member States for commercial purposes (Summary comments…
The Physical, Human Driven Digital Economy: The Overvaluation of Intangibles and its Effects on Tax and Society
…intangible something, and based on a multiple of studies, intangible assets by digital, data- and technology-driven companies might currently be overvalued. The potential consequences of such overvaluation could not only…
The EU Principles Inspire the Italian Excise Tax Reform
…excise duty, provided that such taxes comply with the Community rules applicable to excise duties or VAT in the matter of determining the tax base, calculation , chargeability and control…
Newly proposed VAT rules for sharing economy platforms – some fine-tuning needed?
…and passenger transport sector. In keeping with the principle of proportionality, the Commission proposed deemed supplier rules only in sectors where disruption of competition with the traditional sector is most…
Arm's Length, DEBRA, Deduction, Digital services tax, Intertax, Pillar II, Tax Theory, Unitary Taxation
The Contents of Intertax, Volume 51, Issue 04, 2023
…& Caren Sureth-Sloane, Towards an Amended Arm’s Length Principle: Tackling Complexity and Implementing Destination Rules in Transfer Pricing The arm’s length principle (ALP) is the cornerstone of multinational enterprises’ (MNEs)…
The OECD’s First Inclusive Forum on Carbon Mitigation Approaches: This will need to be far more nimble and conceptually inclusive than the OECD’s approach to date to have global impact
…of international policy coherence and co-ordination. The OECD’s publicly stated plan going forward is to collect and then ‘produce comprehensive and systematic data, information, and tools to analyse the effects…
Book-Tax Conformity for BEFIT: Really the Eternal Return?
…Commission. [1] EUROPEAN Commission, COMMUNICATION FROM THE COMMISSON TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Business Taxation for the 21st Century, COM(2021) 251 final, (BEFIT initiative) pp. 11-13. [2]…
An evaluation of Australia’s Advance Pricing Arrangement program in light of the OECD’s Bilateral Advance Pricing Arrangement Manual
…[14C]. [16] OECD (n 1) 66. [17] PSLA 2015/4 (n 8) [16]. [18] ‘Comparison between audit and advance pricing arrangement features’, ATO (Web Page, 9 August 2022) <https://www.ato.gov.au/business/international-tax-for-business/in-detail/advance-pricing-arrangements/?page=4#Comparison_between_audit_and_advance_pricing_arrangement_features>. [19] OECD…