By Pramod Kumar Siva and William Byrnes of Texas A&M Law1. Previous Comments, Recommendations, and Policy Analysis to the OECD and UNPramod Kumar Siva and I have been closely following and…
1. IntroductionThe global minimum tax (Pillar Two) was implemented in the European Union in December 2022 through Directive (EU) 2022/2523 . At its core lies a system of “top-up tax” whereby the…
Highlights & Insights on European Taxation Please find below a selection of articles published this month (September 2025) in Highlights & Insights on European Taxation, plus…
A Münster Fiscal Court’s late 2023 judgment illustrates a structural fault line in European tax law: while EU law promises free movement of capital, national courts continue to prioritize…
The Indian Supreme Court has again expressed its views on the meaning of PE in the context of franchise arrangements for the operation of hotels in India under a well known brand. It also reflects a…
1. IntroductionEarlier this year, the 2024 update of the OECD Investment Tax Incentives Database (ITID) was published. The ITID provides useful information on the design, eligibility…
On 17 July 2025 the Belgian Constitutional Court requested a preliminary ruling from the Court of Justice of the European Union (CJEU) regarding the compatibility, and by extension the…
This contribution analyzes the recent instability and uncertainty affecting the international tax landscape as of mid-2025 and identifies the key items to monitor regarding the evolution of the…
Giorgio Beretta (Editor) (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam) and Dennis Weber (Editor) (Amsterdam Centre for Tax Law (ACTL) of the University of…
From Pramod Kumar Siva and William Byrnes of Texas A&M University Law's International Tax Risk Management Graduate ProgramRe: Workstream I (Framework Convention), Workstream II (Protocol on Cross…
