Introduction
One of the key reasons highlighted by OECD imploring the urgent need for consensus on digital tax under its Inclusive Framework were the repercussions arising on account of unilateral…
In a prior blog, the author highlighted some of the most frequent debates arising from VAT and the public bodies’ activities or, more generally, the activities subsidised by public bodies.
One key…
The legal framework of the activities carried out by public bodies
The Value Added Tax (VAT) is a consumption tax paid by entities or individuals who, independently, carry out an economic activity,…
With a judgment rendered on 27 November 2020 (case no. 2C_835/2017), the Swiss Federal Supreme Court (“FSC”) confirmed a decision by the Federal Administrative Court (“FAC”) of 24 August 2017 (…
The newly concluded Trade and Cooperation Agreement between the EU and UK has limited provisions concerning taxation, but interesting provisions relevant to interpretation of treaties including good…
As this year 2020 is withering and will soon be gone, it is an understatement that we all will find it hard to not look at the past year with regret. Almost since its first inception days, this year…
The U.S. has a highly successful international financial service industry that is important to the U.S. economy, exemplified by, firstly, the international financial centers such as Miami and New…
On 15 July 2020, the European Commission (EU Commission) unveiled a Proposal for a Council Directive amending Directive 2011/16/EU on administrative cooperation in the field of taxation (the so-…
Purpose of the blog: To analyze the recent ruling of the US tax court (‘the Court’) in the case of The Coca-Cola Company (TCCC).
Ruling: The US Tax Court, for the years 2007-09, ruled TCCC was under…
We commend the OECD’s 15-year effort since its 2005 publication of E-commerce: Transfer Pricing and Business Profits Taxation to address the challenges arising from the digitalization of…