Just two weeks ago on 8 October 2021, 136 of 140 member countries of the OECD/G20 Inclusive Framework agreed on a global tax deal that also features the GloBE international effective minimum tax (the…
For some time now, Poland and Hungary have been under scrutiny from the European Commission for their violation of the rule of law, as we read with some regularity in the daily press. Recently,…
Comment on the decision of the ECtHR in the case ‘Halet against Luxembourg’ (‘Lux Leaks’ case).
In a judgment delivered on 11 May 2021,[i] the Third Chamber of the ECtHR ruled, by five votes…
Though India has been having tax treaties with over 90 countries across the globe for several decades now, interpretation of various provisions of the treaties continues to be a subject matter of…
A conversation on International Tax Practice culminated into an IFA webinar series on May 20th with global experts sharing their perspectives on landmark treaty and transfer pricing rulings…
Introduction
In two previous posts on this blog (1 and 2), the author analyzed the VAT treatment of activities carried out by public entities, particularly public entities that offer radio and…
Bram Markey – EMEA Leader Tax Controversy & Dispute Resolution at PwC Belgium
Raphaël Devroye – Transfer Pricing Manager at PwC Belgium
In a recent judgement[1], the Belgian Court of Appeal of…
Apropos Molinos Rio de la Plata SA
1. Background: Memorandum DNI 799/10
In Memorandum 799/10, the Argentine Competent Authority (Argentine Tax Directorate, Dirección Nacional de Impuestos or DNI)…
Omar Sebastian Cabrera [1]
General considerations
Law 2133, dated August 4, 2021, implemented a new tax regime related to the flagging of ships and vessels in Colombia. The purpose of this law is to…
In the first part of this article, the authors provided an overview of the Blackrock case. In the second part of this article, the authors consider the DBKAG case and reflect on the impact that these…
