A world of tax without disputes is an illusion. It is just as much an illusion as a world without tax. Tax and disputes come together inseparably. Disputes is not something to be ashamed of – I say…
In March 2017, the OECD and the IMF published a report on tax uncertainty (Report) confirming that such uncertainty exists and impacts on business and investment. Similar was the outcome of an…
General
On February 9, 2017, the Court of Justice of the European Union (‘CJEU’) rendered its decision in the X v Staatssecretaris van Financiën (‘X’). The case concerned the possibility of…
Introduction and EU law applicable
On 8 March 2017 the Court of Justice of the European Union (hereafter “CJ”) delivered its decision in the Case C-448/15, Wereldhave, dealing with the interpretation…
On 16 February 2017 the Public Consultation on the proposed introduction of rules at EU level to disincentivize promotion of aggressive tax planning schemes was closed. The rules under consideration…
The Italian Supreme Court issued a landmark case (n. 27113 December 2016) setting out the principles to be taken into account when analyzing whether a company can be deemed the “beneficial owner” for…
Much changed in the world of taxation the last couple of years. The OECD started and finished the BEPS (Base Erosion and Profit shifting) project. The objective of BEPS was to develop rules that…
Italy has embarked upon the challenging task of redesigning its tax system. The Act[1] of late November 2016 (hereinafter, “Act”) constitutes a best-practices example, or at least for our Country…
The European Union’s Court of Justice finally rendered its judgement in the famous Banco Santander and Autogrill cases on 21 December 2016. For state aid specialists and tax lawyers this decision was…
