In the last years, we have witnessed many reforms to make the EU VAT system more consistent and business friendly. The Quick Fixes, which took effect on 1 January 2020, sought to harmonize some of…
Since 2013 the OECD has worked on forging a grand coalition (now 136 countries) it calls the “Inclusive Framework” around adopting the outcomes of the OECD’s Base Erosion and Profit Shifting (BEPS)…
Tax Administration Announces New Control Project
The Finnish Tax Administration has announced that it will be tackling arrangements to avoid withholding tax on dividends. According to the Tax…
1. Purpose of the blog
This contribution is a follow up to the previous contribution of the author. The objective is to address the tentative impact of the Pillar I debate on decentralized MNE…
The Canadian Federal Court of Appeal has upheld the Tax Court of Canada decision in Canada v. Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 (CanLII). The case is of some significance because the…
1. Purpose of the contribution
The purpose of this contribution is to address the impact of the Pillar I debate on principal structures or centralized business models. The tentative assessment will…
Online platforms are an important part of the digital economy and one of the key enablers of the tremendous growth of the e-commerce sector. According to data published by Ecommerce Europe, business-…
The Spanish government approved, on 18 February 2020, a bill for a digital service tax (DST) for discussion by the parliament[1]. The current government has a majority consensus on the new tax with…
In my previous post, I had discussed the judgment delivered in the case of Elsevier Information Systems Gmbh v. Dy. Commissioner of Income Tax which discussed the liability of the taxpayer when it…
This is not a technical commentary. It does not react to a ‘new’ development or case. But these comments do try to focus on understated rudiments of the present international tax debate which may…
