Reader in Tax Law, King’s College London (Autumn 2024)
The past 30 June 2024 was anticipated to be a historic moment. Inclusive Framework’s (IF) countries, both developed and developing, were…
Ricardo García Antón*
The rapid developments in international taxation in the aftermath of the latest financial crisis (2010s), i.e. the fight against tax evasion and tax avoidance, the Pillars’ work…
Highlights & Insights on European Taxation
Please find below a selection of articles published this month (June 2024) in Highlights & Insights on European Taxation, plus one freely accessible…
On Friday, the U.S. Supreme Court issued its expected overruling of the Chevron doctrine, which has been relied upon in 70 past Supreme Court decisions and approximately 17,000 in the Appellate and…
At the end of 2017, Congress passed a once-off Mandatory Repatriation Tax (the “MRT”) of 8 to 15.5 percent of the undistributed total accumulated income of American-controlled foreign corporations…
Introduction
Throughout my professional life, I have worked with international tax law. Consequently, I have witnessed various trends and tendencies for more than a quarter of a century. The period…
Incongruence between Taxation and Representation in the 21st Century from a European Union (EU) Perspective
The phenomenon of increasing mobility of individual taxpayers is manifesting itself all…
Issues involving controversy surrounding the operation of the newly devised Pillar Two rules in company taxation seem to have moved strikingly up business agendas and political agendas recently.…
Highlights & Insights on European Taxation
Please find below a selection of articles published this month (May 2024) in Highlights & Insights on European Taxation, plus one freely accessible…
The recent English Court of Appeal decision in Hargreaves Property Holdings Ltd v HMRC [2024] EWCA Civ 365 http://www.bailii.org/ew/cases/EWCA/Civ/2024/365.html has again examined the meaning of…