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…
Equality is one of the core values of modern democratic societies. It is no accident that equality featured in opening preamble to the United States Declaration of Independence in 1776 and the first…
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…
Some four years ago in this blog, I wrote about problems that would start to emerge as exchange of information between tax administrations became more routine and extensive. If nothing else, the…
Income tax rules are under great pressure internationally, because multinational enterprises, such as Apple, Facebook and McDonald’s, and rich individuals, such as Messi and Ronaldo, avoid or evade…
In my International Taxation class tomorrow (October 10th) we are going to discuss the OECD's “Unified Approach” released a day earlier on October 9, 2019. Given the keen interest generated by…
India recently notified a Protocol that amends the India-China tax treaty and incorporates some of the OECD recommendations put forth as part of its BEPS project. The changes would apply from the…
On 10 September Wolters Kluwer organized an interesting discussion on Permanent Establishments. The discussion was led by 3 panelists, Tamara Schwärzler (PwC Switzerland); Arvid A. Skaar (Norwegian…
The OECD Work Programme published in May of this year under the OECD/G20 Inclusive Framework on BEPS aims to achieve a consensus solution to the problems of taxing the digital economy.
The OECD Work…