On July 13, 2018, India’s Central Board of Direct Taxes (CBDT) issued for stakeholders’ comments a consultation document on framing of tax rules in respect of the concept of “significant economic…
I am delighted to see that my post on value creation has stimulated discussion on the fundamental thinking about international taxation. See the posts of my friends and colleagues Werner Haslehner…
“Those who cannot remember the past are condemned to repeat it” George Santayana, The Life of Reason: Reason in Common Sense (1905).
A seminar was held in Rotterdam on 18 May 2018 on “value creation”…
Introduction
As the General Reporter for the Subject 2 (The Future of Transfer Pricing) of the 2017 IFA Congress in Rio de Janeiro, I joined the plenary session on August 29 in a panel chaired by…
On 6 March 2018, the CJEU has issue its judgment on the case Achmea BV (C-284/16 here), that can impact many areas of the EU law, including tax matters.
The Court states that “Articles 267 and 344…
On 6 March 2018 the Grand Chamber of the CJEU ruled in the Achmea decision (C-284/16) that the bilateral investment treaty (BIT) between The Netherlands and the Slovak Republic violated EU law…
On 21 March, the European Commission will publish a proposal for a two-fold strategy to reform the taxation of digital companies like Google and Facebook. The most recent draft of the proposal that…
The Spanish Supreme Court recently issued (February 19, Spanish version here) a long awaited judgment confirming that the Spanish inheritance tax legal framework breaches the free movement of capital…
Non-inclusion of the Swiss-United Kingdom income tax treaty in the list of Covered Tax Agreements of both the states on signing the BEPS MLI on 7 June 2017 surprised some observers. This evident gap…
