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Abuse of law, Anti-tax avoidance, Beneficial ownership, Canada, Direct taxation, Dividends, Double non-taxation, Double Taxation, DTA, Finance, Financial transactions, Holding company, International Tax Law, OECD, Tax Treaties, Treaty shopping, Withholding Taxes

(Temple Tax Chambers; King’s College London)/ /2 Comments

…companies in respect of shares that were loaned by Barbados resident companies to Luxembourg resident companies. A dividend paid by a Canadian company to a Barbados resident in these circumstances…

GloBE, GloBE Rules, Oil and Gas, Pillar II

(Senior petroleum legal analyst, S&P Global)/ /Leave a comment

…  Alessandro Bacci, Senior Petroleum Legal Analyst, PEPS, S&P Global Commodity Insights LinkedIn: Alessandro Bacci | LinkedIn Twitter: Alessandro Bacci (@AlexMiddleEast) / X (twitter.com) Email (work): alessandro.bacci@spglobal.com Email (personal): alessandro.bacci.fossi@gmail.com…

DAC 7, Digital economy, Digital platforms, EU

(Visiting Professor UAntwerp, UHasselt and EY Belgium) and (University of Amsterdam - Loyens & Loeff)/ /Leave a comment

…[13] DAC7, Annex V, Sec. I., A., 10. [14] DAC7, Annex V, Sec. I., A., 11. [15] https://www.forbes.com/sites/mattklein/2020/09/23/50m-join-the-creator-economy-as-new-platforms-emerge-to-help-anyone-produce-content–money/. [16] https://www.goldmansachs.com/intelligence/pages/the-creator-economy-could-approach-half-a-trillion-dollars-by-2027.html. [17] This is because, the promotional service rendered by DCCs…

Advance pricing agreement, Anti-tax avoidance, BEPS, Corporate income tax, DEMPE, Intangibles, International Tax Law, IP, MAPs and APAs, MNE Profits, OECD, Tax Avoidance, Transfer Pricing, United Kingdom

(Temple Tax Chambers; King’s College London)/ /Leave a comment

…Refinitiv, intellectual property was centrally held within the Thomson Reuters group by a Swiss resident company. UK resident group companies provided services to the Swiss company. The services were described…

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

…LEGISLATION – CBAM Implementing Regulation for the Transitional Phase (comments by Tatiana Falcao) (H&I 2023/313)   INDIRECT TAXATION, CASE LAW – Hauptzollamt Münster (C-7/20). VAT on importation. Failure to comply…

BEFIT, Corporate income tax, European Commission

(Erasmus School of Law, Erasmus University Rotterdam, PwC Rotterdam) and (Assistant Professor at the University of Amsterdam /Senior Manager Tax at PwC Netherlands Tax Knowledge Centre.)/ /Leave a comment

…Commission, Proposal for a Council Directive on a Common Corporate Tax Base, COM(2016) 685 final, 25 October 2016 (withdrawn). [3] See European Commission, Proposal for a Council Directive on a…

BEFIT, Corporate income tax, European Commission

(Erasmus School of Law, Erasmus University Rotterdam, PwC Rotterdam) and (Assistant Professor at the University of Amsterdam /Senior Manager Tax at PwC Netherlands Tax Knowledge Centre.)/ /Leave a comment

…Tax Base, COM(2016) 685 final, 25 October 2016 (withdrawn). [3] See European Commission, Proposal for a Council Directive on a Common Consolidated Corporate Tax Base, COM(2016) 683 final, 25 October…

Customs and Excise, Direct taxation, EU, 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

…AID – Banco Santander (T-12/15, T-158/15, and T-258/15). Annulment of Commission’s decision on Spanish tax scheme. General Court (comments by Raymond Luja) (H&I 2023/264)   FREE ARTICLE – Zes Zollner…