On 6 March 2018 the Grand Chamber of the CJEU ruled in the Achmea decision (C-284/16) that the bilateral investment treaty (BIT) between The Netherlands and the Slovak Republic violated EU law…
Increased focus on taxation of cross-border situations involving both individuals and companies is one of the key features of the post-BEPS international tax environment. One central aspect of this…
Introduction
The financial crisis had made multinational enterprises (MNE) look inward for funding options, as external sources of capital were not readily available. Among various intra group-…
On 21 March, the European Commission will publish a proposal for a two-fold strategy to reform the taxation of digital companies like Google and Facebook. The most recent draft of the proposal that…
The Spanish Supreme Court recently issued (February 19, Spanish version here) a long awaited judgment confirming that the Spanish inheritance tax legal framework breaches the free movement of capital…
Non-inclusion of the Swiss-United Kingdom income tax treaty in the list of Covered Tax Agreements of both the states on signing the BEPS MLI on 7 June 2017 surprised some observers. This evident gap…
On February 1, 2018, Indian Finance Minister presented the country’s latest Budget, which contains an international tax proposal that may not send a positive message to foreign companies doing…
At the current stage, it is difficult to predict a potential application of the principal purposes test (PPT) and its outcome since it has not entered into force in the 72 Signatories of the…
It is 30 December and 2 MNEs contact me about my YouTube videos on uploading Country by Country Reports (CbCRs); they need help. In the week of New Year, I helped taxpayers in Bermuda, Belgium,…
Among the main issues the BEPS project intends to address is the phenomenon of “double non-taxation”. It is a term that is used quite frequently nowadays; primarily in order to describe situations…
