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…
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…
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…
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 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…
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…
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…
[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…
Context Italy is well known for its cultural heritage, amazing landscapes, vibrant SMEs, brands, skilled work force and many other features, including its food…. It is also known in the international tax world for the advances of its tax administration towards more efficient and innovative practices, such as electronic invoicing, pre-filled tax returns, and the…
The DAC8 proposal published on 8 December 2022 represents the most recent effort of the European Commission to enhance administrative cooperation in the tax field. It aims to include crypto-assets under the existing EU framework for the exchange of information. This way, the Commission’s work is intended to address the challenges associated with the increasing…
Highlights & Insights on European Taxation Please find below a selection of articles published this month 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…
Should services performed by a member of a board of directors towards the company of which s/he is a member be subject to VAT? This is a question that keeps many VAT legislators, authorities, and advisors around the world busy. It is an area that has seen numerous changes in tax policy, sometimes as a…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Joachim Englisch, GloBE Rules and Tax Competition This article studies foreseeable effects that a relatively comprehensive implementation of the Pillar 2 GloBE international effective minimum tax would have on international tax competition for investment….
State aid law is closely linked to the Treaty on the Functioning of the European Union (TFEU) commitment to creating, maintaining, and strengthening a common market in which competition is not distorted. Precisely what characterises companies that form part of a group of companies (multinational or not) is that transactions carried out between them are…
