I was recently asked to analyze the often quoted figure of $150 billion lost by the U.S. Treasury to foreign non-tax compliance by U.S. taxpayers. My transcribed remarks are below. Also, see…
Introduction and EU law applicable
On 8 March 2017 the Court of Justice of the European Union (hereafter “CJ”) delivered its decision in the Case C-448/15, Wereldhave, dealing with the interpretation…
The Italian Supreme Court issued a landmark case (n. 27113 December 2016) setting out the principles to be taken into account when analyzing whether a company can be deemed the “beneficial owner” for…
On February 1, 2017, India’s Finance Minister, Arun Jaitley, presented the country’s 2017-18 Budget, which contains several tax proposals in the area of international tax law, including the…
There are several misconceptions in international taxation, some of them more pervasive than others. Many are often repeated by speakers at tax conferences without being contradicted.
The first is…
Probably without noticing it, Colombia did not take into account that signing the recent DTT with France would allow some treaty-covered taxpayers to claim Most-Favoured-Nation (MFN) protection.
Some…
When UK voters went to the polls on 23 June 2016 and voted by a slim majority to leave the European Union, few of them had in mind the impact on taxation. Future generations are unlikely to view it…
1. The Tendency
We live in a time where the media, politicians, NGOs and activists increasingly are preoccupied with international tax matters. A simultaneous preoccupation is observed among the OECD…
“Starbucks tax deal equals inadmissible state aid”: it was with this headline that newspapers reported on 21 October 2015 that the European Commission – instigated by Margrethe Vestager, the European…
