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Jonathan Schwarz (Temple Tax Chambers; King’s College London)

Mutual Administrative Assistance in Tax Matters: Limits on Assistance

January 21, 2026

The recent decision of the Federal Court of Canada in Canada (National Revenue) v. Shopify Inc. (2025 FC 968) is a rare decision on the Joint Council of Europe/OECD Convention on Mutual…

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Leopoldo Parada (Reader in Tax Law, King’s College London )

The SbS Package and the Irony of Global Tax Cooperation

January 20, 2026

IntroductionOn 5 January 2026, the OECD Inclusive Framework announced what many have heralded as a breakthrough: the Side-by-Side (SbS) Package. The package was presented as evidence of the maturity…

Mukesh Butani (Managing Partner at BMR Legal), Pranoy Goswami, Spandana Koona (BMR Legal)

A Kaleidoscope for an Equitable and just Future: Examining the Merits of the Draft Text of the United Nations Framework Convention on International Tax Cooperation

January 14, 2026

Addressing entrenched inequalities permeating society, has been the concern of political justice. So though the term justice has assumed importance in the realm of political science, it is quite…

Jasper Korving (Maastricht University; Deloitte Tax & Legal BV)

Side-by-Side as discordant constitutional element: what can EU Member States do?

January 12, 2026

1. IntroductionAfter lengthy discussions at OECD/Inclusive Framework level, the Global Minimum Tax Rules – or Pillar Two rules – were adopted on 20 December 2021. Two days later, the European…

Dennis Weber (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff)

The Pillar 2 - Side-by-Side Package: A Structural Breach of EU Tax Law

January 8, 2026

IntroductionThe publication of the OECD Pillar 2 Side-by-Side (SbS) Package marks a decisive moment in the evolution of the Global Minimum Tax (Pillar 2 or GloBE ) and its interaction with EU…

Giorgio Beretta (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University), Dennis Weber (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff)

The Contents of Highlights & Insights on European Taxation

January 5, 2026

Please find below a selection of articles published this month (December 2025) in Highlights & Insights on European Taxation, plus one freely accessible article.Highlights & Insights on European…

Dennis Weber (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff)

The EU 28th Regime for Innovative Companies Needs a Dual-Instrument Architecture to stimulate a Coherent Tax Treatment

December 29, 2025

The European Union currently comprises twenty-seven Member States, each maintaining its own rules on company law, labour relations, insolvency and taxation. The European Commission’s proposal for a …