1. Carve-out of financial services from the scope of Amount A
According to the Report on the Pillar One Blueprint,[1] the proposed scope of Amount A is designed to capture multinational groups that…
In October 2020, the OECD Secretariat published the ‘Report on Pillar One Blueprint‘ approved by the Inclusive Framework on BEPS as a result of the work on the tax challenges arising from…
1. Introduction
The Pillar Two Report[1] (the “Report”) which contains the Global Minimal Tax (the “GloBE tax”) proposal has recently been on the top of discussions both in the academic and practice…
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…
1. Introduction
The ability to stimulate economic activity and to attract foreign capital and investments through national tax policies has been known for many centuries. It was in the middle of the…
Those with a long memory for cricketing events may remember the 1996 World Cup hosted jointly by India, Pakistan and Sri Lanka. The winner, Sri Lanka, made 398 runs for 5 wickets, in a one-day…
Tatiana Falcão[1]
On 22 July 2020 the European Commission opened a public consultation on the Carbon Border Adjustment proposal put forward as part of the EU Green Deal. This is not the first…
This article is the last of a series of three posts dealing with non-chargeable intra group services: Shareholder Activities, Duplicate Activities and Incidental Benefits. This post will specifically…
In Part 1, we discussed in a first step the ground barrier for taxing data in the context of international taxation: a proper definition of data. In a second step, we showed you which negative…
