The Champions League is back in town and tonight, its iconic hymn echoes through the speakers of Europe’s greatest clubs’ mostly empty stadiums: "Die Meister! Die Besten! Les grandes équipes! The…
Introduction
India’s 2021 Finance Bill proposes to add a definition of “liable to tax” in its domestic direct tax law. As per the definition, the term ‘liable to tax’, “in relation to a person, means…
As the Blueprint on Pillar I illustrates, the political and technical complexities inherent to the solution sought by OECD are of such magnitude, that such a sole fact opens the window to an…
Introduction
In today’s world, many things have become more intuitive – user interfaces of electronic devices, the way the merchandise is advertised, and how information is delivered. This contention…
HMRC v Embiricos [2020] UKUT 370 (TC) reflects a common issue that arises in connection with tax investigations or audits of internationally mobile individuals. Mr Embiricos filed his tax returns on…
In part 1 of this blog, we focused on the increased involvement of platforms in the levy of direct and indirect taxes. In this blog, we will highlight other digital economy tax trends, such as the…
The digitization and globalization of the economy have created a challenging environment to enforce tax rules and ensure tax compliance. Ever since the OECD’s release of the Action Plan on Base…
Open to public
On 27 and 28 January 2021, the 11th meeting of the OECD/G20 Inclusive Framework on BEPS was held. For the first time, a meeting of the Inclusive Framework was open to the public. Even…
Introduction
Let’s assume the following situation: ParCo is the parent company of a multinational group with its residence in Switzerland and engaged in the automotive business. It developed an…
After the initial relief that followed upon reaching a Trade and Cooperation Agreement between the European Union and the United Kingdom on Christmas Eve, we slowly see how this treaty is going to…
