What does the notion of “aggressive tax strategy” mean for the quest for tax justice and what are its consequences on environmental, social and governance matters?[1] In my opinion, an enterprise’s…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:
Stefanie Geringer, The EU’s Uncoordinated Approach to Tax Avoidance and Tax…
English may be the lingua franca of our time, but it is not the only language of international law. Royal Bank of Canada v HMRC [2022] UKUT 45 (TCC). raised issues around the interpretation of a tax…
The Court of Justice of the European Union (CJEU), by means of an Order in Case C-255/20 of 9 November 2021 [1], established the incompatibility with EU law, in particular with Directives 2008/118/EC…
Prof.M.F. (Maarten) de Wilde[1]
Summary
Yesterday, on 14 March 2022, the OECD published the Commentary on the Pillar 2 Model Rules, the global minimum rate for large multinationals. When reading the…
In the first part of this two-piece article titled “Croatia: A New (Tax-Free) Promised Land for Digital Nomads? (Part I)”, we provided an overview of the new Croatian normative framework applicable…
The concept of “digital nomadism” has emerged in popular literature some 25 years ago, in a thought-provoking and prescient book co-authored by Tsugio Makimoto and David Manners.[1] Put simply, the…
Territorial connection (or its more fashionable name “nexus”) for tax purposes is expressed in a variety of ways in domestic and international legal instruments. Permanent establishment in article 5…
Trésor-Gauthier M. Kalonji [1]
Summary
The Covid-19 pandemic has shaken several rules applicable in conventional tax law, in particular with regard to determining the conditions for qualifying a "…
Abridged comments for a regional appraisal and possible outcomes to implementation
2010-2020: A Decade of Profound Changes in International Taxation
Following the world financial crisis, the…
