Two cases, currently before different courts highlight long-standing questions around the attribution of profits to permanent establishments. Irish and United Kingdom law on the attribution of…
May linking rules related to hybrid financial instruments be incompatible with the EU Fundamental freedoms? And with Article 24 (4) OECD MC? What about treaty override?
It is no secret that hybrid…
On 14 November 2019, AG Kokott released her opinion in Dong Yang Electronics (Case C-547/18), referred to the Court of Justice of European Union (CJEU) by the Regional Administrative Court of Wroclaw…
In June 2017, the European Commission published its proposal on transparency rules for tax planning by intermediaries and certain taxpayers (the Commission proposal). The Commission proposal was…
The past few years have seen the sensational rise of new models of production, distribution, and consumption of goods and services, which have been synthetically captured under the umbrella…
Not the Hungarian Constitutional Court but maybe AG Kokott in her forthcoming opinion in the Google Ireland case…
Optimistically speaking, the Hungarian Advertisement Tax contributes to a large…
Introduction
The new European Commission that is taking shape shall inherit quite a heavy file of initiatives to pursue in the next five years. Certainly, this is the case in the area of taxation…
The judgments of the European Court of Justice (ECJ) on the withholding tax exemption provided by the Interest and Royalties Directive (available here – the ‘IRD judgment’) and the Parent-Subsidiary…
On 16 April 2019, the European Parliament (EP) voted in favour of the proposed Directive on the protection of persons reporting on breaches of Union law (hereinafter "the Directive"). While the…
