Tax authorities have relied on informers for investigative leads perhaps since taxes were first imposed. In the 21st Century high profile cases of theft of taxpayer information by employees of…
The Trade Agreement between the EU and the UK rules out any direct effect. However, the Trade Agreement could have an indirect effect. EU Member States should interpret the capital ownership…
The vexed question of whether country-by-country reports (CBCR) on multinational companies’ tax affairs should be made public[1] has been a recurrent topic in the tax debates for years.
In Europe…
(Forthcoming: Intertax, vol. 49, 2021, issue 8/9)
Like it or not, the Covid-19 pandemic has been changing our way of life. Among others, large-scale lockdowns drive us to work from home and to rely…
The relationship between treaties and domestic tax law ought to be straightforward. The pacta servanda sunt principle expressed in articles 26 and 27 of the Vienna Convention on the Law of Treaties…
“You looking to buy? Everything is tax-free.”
Vendor bot Wallace, Berkeley Springs Station, Fallout 76 videogame
Public interest in taxation is rising in the recent decade. Digital giants and…
(Forthcoming: Intertax, vol. 49, 2021, issue 6/7)
The Spanish digital services tax (hereinafter DST)[1] came into force 16 January 2021 replicating the European draft directive except for some minor…
Today we are witnessing a historic moment in the digitalisation of tax administrations (TAs) which evidently accelerated, unplanned and unforeseen, due to the measures of isolation and closure of…
Analysis of the ECJ judgments, reading by national courts, and impact on tax treaty practice
Authors: Robert Danon,[1] Daniel Gutmann,[2] Margriet Lukkien,[3] Guglielmo Maisto,[4] Adolfo Martín…
1. Introduction
To be able to compete successfully in international markets, companies need to turn their R&D results fast and effectively into marketable products. Thus, besides the development…
