EU/EEA

A global silver alert for fair and efficient tax systems is active already for a couple of years. The heated debate sparked all over the world has engaged national governments, NGOs, international…

The transition from bilateralism to multilateralism in regard of international law-making seems to be a relentless work in progress. Nobody contests that multilateralism would be – legally speaking –…

The Anti-Tax Avoidance Directive (ATAD) is the European answer to the phenomenon of BEPS: Base Erosion and Profit Shifting. Characteristically for tax avoidance by Base Erosion and Profit Shifting,…

As previously reported on this Blog the EU Anti-Tax Avoidance Package was presented on 28th January 2016. The package included: -          Recommendation on Tax Treaties -          Amended Directive…

On September 14th, 2016, the Brazilian Federal Revenue Service (“RFB”) published the Normative Instruction RFB No. 1,658/2016, which included legal entities incorporated as holding companies in…

An important question in the context of the recovery of fiscal state aid, is how the amount of the tax advantage to be recovered should be calculated. Recently, the Dutch legislator released a draft…

Introduction. I have been actively supporting an EU based corporate income tax to reflect the single internal market rather than a fragmented framework with 28 competing tax laws. I’ve done so since…

Tax practitioner’s in the northern hemisphere taking their summer holidays may well have included the OECD discussion draft of 5 July 2016 on the attribution of profits to permanent establishments as…

Much has been written – and probably even more has been said – about the different consequences of the Brexit vote. This is hardly a surprise: the decision is a first in the history of the European…