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Shilpa Goel (Tax Lawyer)
Addressing tax challenges of the digital economy: fair play or foul play?
August 18, 2017

“The judge who always likes the results he reaches is a bad judge,” Justice Antonin Scalia had famously said. A recent ruling delivered by the Bengaluru Bench of the Indian Income Tax Tribunal in ABB…

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Frederik Boulogne (Lubbers, Boer & Douma; VU University Amsterdam)
Safeguarding the financial interests of the Member States under Article 8 of the EU Merger Directive and the pending Marc Lassus (C-421/16) and Finnish exit tax case (C-292/16)
August 15, 2017

The objective of the EU Merger Directive (“MD”) is to remove tax obstacles to cross-border restructuring operations while safeguarding the financial interests of the Member States.[1] In aligning…

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Hans van den Hurk (Professor Maastricht University and (co)owner Cygnus Tax BV, Apertas BV and Herreveld van den Hurk BV (i.o.))
About professional soccer players, sons of God and friends of the devil
August 11, 2017

More and more soccer players hit the newspapers because they are not just creative in the soccer stadiums but also in dealing with their tax returns. Recently we have seen the press reporting on…

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Paolo Arginelli (Catholic University in Italy; Maisto & Associati)
A proposal for harmonizing the rules on the allocation of taxing rights within the EU and in the relations between Member States and third countries: ATRiD and EU tax treaties
August 09, 2017

This contribution lays down a general plan for what the EU should do in order to attain a harmonized set of norms regulating the allocation of taxing rights among Member States and in the relation…

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Jonathan Schwarz (Temple Tax Chambers; King’s College London)
Permanent Establishment: La lutte continue
July 24, 2017

Google’s international corporate structure and operating model has featured significantly in the political and legal debate about the taxation of multinational companies, particularly in the…

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Ramon Tomazela (Mariz de Oliveira e Siqueira Campos Advogados)
Improvements in the OECD's Discussion Draft on Profit Split
July 18, 2017

On 22 June 2017, the OECD released for public comment the revised discussion draft on the application of the profit split method, which intends to continue the work developed in the OECD Transfer…

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Martijn Nouwen (University of Amsterdam and EY), Arjo van Eijsden (EY)
The new transparency rules for intermediaries and companies lead to a complete tax chaos
July 14, 2017

Intermediaries (such as: tax advisors, accountants, banks, and lawyers) who design tax structures are now on the Commission’s radar. She recently proposed extensive transparency rules on the basis of…

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Piergiorgio Valente (Crowe Valente/Valente Associati GEB Partners; Link Campus University, Rome)
Capturing Dematerialized Money through Anti-Money Laundering Provisions
July 12, 2017

The Committee on Economic and Monetary Affairs and the Committee on Civil Liberties, Justice and Home Affairs of the European Parliament recently finalized the amendments to the existing Anti-Money…

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Shilpa Goel (Tax Lawyer)
BEPS Multilateral Instrument: Where India Stands
July 10, 2017

On June 7, 2017, India joined more than 65 countries in signing the OECD’s Multilateral Instrument to implement tax treaty-related base erosion and profit shifting (BEPS) recommendations. The…

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Paulina Szotek, LL.M. (Maastricht University )
Is the EU council about to confirm the existence of an EU at arm’s length principle?
July 06, 2017

On 21 June 2017, the European Commission released its Proposal on transparency rules for tax intermediaries. It primarily seeks to address concerns raised by the ECOFIN Council and the European…

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