1. Carve-out of financial services from the scope of Amount A
According to the Report on the Pillar One Blueprint,[1] the proposed scope of Amount A is designed to capture multinational groups that…
The Italian legislation on excise duties, and in particular Article 24 of Legislative Decree no. 504 of 26 October 1995 (hereinafter, “the Italian Excise Duties Act”) that provides an exemption for…
On 10 July 2020, the Italian Supreme Court (also ‘Court’) issued its decision No. 14756 (‘Decision 14756/2020’, published in H&I 2020/470 with comments by Arginelli and Tenore) dealing, amongst…
When the UK introduced its diverted profits tax, I was telephoned by a lawyer at the US Treasury. He wanted to know whether the “just and reasonable” apportionment of profits, in certain…
The Revenue Agency confirms the exemption of income derived abroad by foreign maritime employees who are tax residents of Italy
The Italian Revenue Agency has recently issued a ruling (No. 134/2020)…
In October 2020, the OECD Secretariat published the ‘Report on Pillar One Blueprint‘ approved by the Inclusive Framework on BEPS as a result of the work on the tax challenges arising from…
1. Introduction
The Pillar Two Report[1] (the “Report”) which contains the Global Minimal Tax (the “GloBE tax”) proposal has recently been on the top of discussions both in the academic and practice…
One objective of Estonian Tax and Customs Board (ETCB) is to provide simple and convenient services to taxpayers. To achieve this, the ETCB has invested significant amount of resources to enable…
Since the OECD introduced its Global Anti-Base Erosion Proposal (GLoBE) in early 2019 as the second pillar of the ongoing search for a solution to the tax challenges of the Digitalisation of the…
State of affairs
Over the last two decades, eminent scholars and commentators have been highlighting the numerous issues arising from the current regime governing insurance and financial services as…
