BEPS Action 5: Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance, Action 5: 2015 Final Report defined a “preferential” tax regime as one that …
Pope Leo XIV’s Magnifica Humanitas, published on the 135th anniversary of Rerum Novarum, calls for data to be treated as a common good. It denounces a new form of digital colonialism, where user data…
Please find below a selection of articles published this month (June 2026) in Highlights & Insights on European Taxation, plus one freely accessible article.Highlights &…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:Sourcing the Unsourceable: Cross Border Tax Implications of Cryptographic…
The United Kingdom First-tier tax Tribunal has declined to order the disclosure of a US parent company's group consolidated financial statements and US entity level financial statements in a…
Bilateral tax treaties prevent double taxation in several ways. One is by identifying a taxpayer’s residence (“treaty residence”) and reserving taxing rights to that state alone. Anti-abuse rules ask…
This piece examines the CFC carve-out in the reportedly leaked EU Tax Omnibus proposal and argues that, rather than simply reducing overlap with Pillar Two, it introduces a layered exemption that…
Please find below a selection of articles published this month (May 2026) in Highlights & Insights on European Taxation, plus one freely accessible article.Highlights &…
In an era where tax administrations seek increasing amounts of information from taxpayers and others, and where the routinely exchange information with each other, a recent decision of the European…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:‘Gross’ly Overlooked: The Difficulties of Implementing the New Article 12AA…
