There's something about OECD's Pillar One. For some years now, the world has been under the spell of a new system of taxation of companies that make profits in countries without taking root there in…
Introduction
Article 11 of the VAT Directive allows EU Member States (MS) to regard as a single taxable person a group of persons established in their territory who, while legally independent, ‘are…
On 1 July 2019, the Dutch tax ruling practice was revised to align it with EU and international standards and recommendations as well as to increase its openness and transparency. In this respect,…
Articles 3 and 6 ATAD: a dangerous EU legislative mix
In the forthcoming issue of Intertax, I make an in-depth analysis of the issues concerning the partial implementation of the EU GAAR, as…
The Champions League is back in town and tonight, its iconic hymn echoes through the speakers of Europe’s greatest clubs’ mostly empty stadiums: "Die Meister! Die Besten! Les grandes équipes! The…
Introduction
India’s 2021 Finance Bill proposes to add a definition of “liable to tax” in its domestic direct tax law. As per the definition, the term ‘liable to tax’, “in relation to a person, means…
As the Blueprint on Pillar I illustrates, the political and technical complexities inherent to the solution sought by OECD are of such magnitude, that such a sole fact opens the window to an…
Introduction
In today’s world, many things have become more intuitive – user interfaces of electronic devices, the way the merchandise is advertised, and how information is delivered. This contention…
HMRC v Embiricos [2020] UKUT 370 (TC) reflects a common issue that arises in connection with tax investigations or audits of internationally mobile individuals. Mr Embiricos filed his tax returns on…
In part 1 of this blog, we focused on the increased involvement of platforms in the levy of direct and indirect taxes. In this blog, we will highlight other digital economy tax trends, such as the…
