Pramod Kumar Siva and William Byrnes of Texas A&M University School of Law’s International Tax Risk Management graduate programIn response to a question from some of our non-U.S.-educated tax law…
After a decade shaped by the OECD’s BEPS project and successive EU directives aimed at curbing tax avoidance, European policymakers are recalibrating around competitiveness, simplification and…
CUSTOMS AND EXCISE, DIRECT TAXATION, EU LAW, INDIRECT TAXATIONPlease find below a selection of articles published this month (October 2025) in Highlights & Insights…
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…
