Since the OECD introduced its Global Anti-Base Erosion Proposal (GLoBE) in early 2019 as the second pillar of the ongoing search for a solution to the tax challenges of the Digitalisation of the…
Many States have incorporated General Anti-Avoidance Rules (GAARs) into their tax laws to prevent tax avoidance; within the EU, a GAAR is even mandatory for corporate taxation since 1 January 2019 …
It may well be said that George and Ira Gershwin’s simple and unforgettable line, “Let’s call the whole thing off!”, sums up the European Commission’s (“Commission”) view that the “wholly artificial…
