OECD

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…

For international tax law, it is of central importance how to locate, value & control the increasingly digital cross-border supply and service relationships within a multinational enterprise (MNE)…

A couple of days ago, in the last weekly session of the Indiana-Leeds Summer Tax Workshop, I attended the presentation of a fascinating paper by Steven A. Dean (A Constitutional Moment in Cross…

Following the Supreme Court decision in Fowler v HMRC [2020] UKSC 22, the UK First-tier Tribunal has considered another case where classification of a source of income for tax treaty purposes was in…