The Contents of EC Tax Review, Volume 32, Issue 02, 2023
…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 compensation paid for funds put…
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New tax podcast on Pillar 2 – International Law Talk series
…Rules and the compatibility of these rules with Tax Treaties, EU Tax Law and the broader international law framework. You can listen to the trailer below. http://wolterskluwerblogs.com/tax/wp-content/uploads/sites/59/2023/03/KLI-24-trailer-mp3.mp3 …
The Contents of Highlights & Insights on European Taxation, Issue 2, 2023
…to respect for communications with client (comments by Edwin Thomas) (H&I 2023/5) STATE AID – Tackling distortive foreign subsidies on the internal market. Council (comments by Raymond Luja) (H&I…
The Contents of Intertax, Volume 51, Issue 03, 2023
…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) dividends are encompassed within the…
Changes in the Spanish Use and Enjoyment Vat Rule as of 1 January 2023
…gave a certain comfort to taxpayers. However, as the author pointed out, this criterion has not remained static but evolved towards a broader application adding more complexities to the process….
Digital Services Taxes in the European Union: What Can We Expect?
…Digital Presence, COM(2018) 147 final (21 Mar. 2018); and European Commission, Proposal for a Council Directive on the Common System of a Digital Services Tax on Revenues Resulting from the…
The 3M Decision: Did Treasury or Congress Overturn Past Jurisprudence?
…this regulation are not clear cut. [1] 3M v. Commissioner, 160 T.C. No. 3 (Feb. 9, 2023) addressing the validity of Treasury Regulation § 1.482-1(h)(2). [2] Amazon.com, Inc. v. Comm’r,…
The Contents of Highlights & Insights on European Taxation, Issue 1, 2023
…Bremen (C-431/21). Tax surcharge for non-compliance with obligation to keep documents on cross-border business transactions between related companies. Court of Justice (comments by Edwin Thomas) (H&I 2022/371) INDIRECT TAXATION,…
India’s Budget 2023 – A move towards trust-based governance
…companies – these have now been extended to notified non-banking financial companies (NBFCs). This is a welcome move – NBFCs are regulated when it comes to leverage. Audits The timeline…
Windfall profits in the Energy Sector in 2022: Which entity in the group should capture them? – A transfer pricing perspective
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…
The Contents of Intertax, Volume 51, Issue 02, 2023
…the acceptance of almost all common accounting standards under Pillar Two incentivizes generally accepted accounting principles (GAAP) competition between countries. The authors conclude that connecting Pillar Two to financial statements…
DAC8: Exchange of HNWI Cross-border Rulings
[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…
The Italian Investment Management Exemption: A New Dawn for Asset Management in Italy?
…effect is short-term (revenue) gains with long-term (economic) pain. In fact this generates a country-risk that is substantially higher compared to other developed economies. This is chiefly because in other…
The DAC8 Proposal and the Future of Crypto-Asset Reporting: Some Preliminary Thoughts
…Secondly, these providers report the collected information to the competent tax authority of the Member State where they are based (for EU providers) or the competent authority of the Member…