Some cases just have it all; the Apple case is one of them. First, size: at more than thirteen billion euros, the recovery order Ireland had to enforce dwarfed the previously biggest one (EDF, at…
The global COVID-19 pandemic that arose in early 2020 could be considered the most disruptive factor the world has witnessed in generations. Paradigms taken for granted until then were upended,…
We are glad to announce that Dr Giorgio Beretta has joined the Kluwer International Tax Blog’s team as an editor, responsible for the new section of the blog dedicated to VAT/GST and indirect…
In the aftermath of the surge in COVID-19 related government support to businesses and just days after UK Brexit negotiators announced not to extend the deadline for the ongoing negotiations with the…
In its judgment of January 21, 2020 (Santander case, available here), the European Court of Justice (ECJ) not only prevented the Spanish Central Tax Tribunal (Tribunal Económico-Administrativo…
The global crisis provoked by the Covid-19 disease has affected several spheres of our lives. Apart from health, the biggest impact has been felt in the reduction of production and consumption,…
The VAT treatment of the issue, acquisition, holding and sale of shares has become a rather complicated affair over the last thirty years. The case law of the Court of Justice of the European Union (…
Duplicate activities?
Duplicate services are defined in the 2017 Transfer Pricing Guidelines (TPG) of the OECD as “activities undertaken by one group member that merely duplicate a service that…
Denmark accepted all MLI articles dealing with PEs, but what does that actually mean? Reading the MLI itself leaves one somewhat bewildered, being thrown back and forth between a variety of articles…
In last month’s blog I promised to address the treaty aspects of Davies and Others v HMRC [2020] UKUT 67 (TCC). The case concerned UK resident individuals who each took out a life insurance policy…
