The Marks & Spencer case (C-446/03), in which the Grand Chamber of the Court of Justice of the European Union rendered its decision that final losses incurred by its non-resident subsidiary can…
According to the OECD’s work “The Role and Design of Net Wealth Taxes in the OECD” (published on April 12, 2018, available here), very few OECD countries still apply net wealth taxes to individuals:…
Can an Indian subsidiary be said to be the permanent establishment of its overseas parent on the ground that it is a virtual projection of the latter even if the tests explicitly stipulated in the…
I am happy to inform you that the latest issue - the August-September double issue - of the journal is now available, and includes many excellent contributions on a varied range of topics, such as,…
The update on tax certainty IMF/OECD Report for the G20 Finance Ministers and Central Bank Governors published on 22 July 2018 may not have been everyone’s summer holiday reading. This report…
On May 11th a very interesting conference with the topic “How Source and Residence have Developed: Rethinking the Principles of International Income Taxation” has taken place, in Bergamo, organised…
India introduced the place of effective management (POEM) in its domestic law in Finance Bill of 2015 but due to lack of preparedness it was deferred to April 1, 2017 and made applicable from…
The first semester of 2018 has witnessed notable – if not unprecedented – activity in the area of tax policy, in the EU as well as internationally. The wind of change tha we sense in international…
Introduction
One of the advantages multinational groups enjoy over standalone companies is that their members have access to each other’s resources (such as, e.g., funding). In particular, less…
What the UK government wants by way of Brexit outcome seems to change daily, with the government and political parties in Parliament divided among various factions. The only legal certainty about…
