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Joachim Englisch  (University of Muenster)
A Carbon Border Adjustment Mechanism for the EU ETS
October 30, 2020

I. Introductory remarks In its recently closed public consultation on a possible carbon border adjustment mechanism (CBAM) for selected sectors as a key element of the EU Green Deal, the EU…

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Mukesh Butani  (Managing Partner at BMR Legal) , Tarun Jain  (BMR Legal)
India’s Dividend Distribution Tax: An Anomaly Outside Tax Treaties!
October 23, 2020

In international customary law, the scope of bilateral tax conventions is not exhaustive and instead limited by the temporal scope set out in ‘taxes covered’ clause. It is true that the scope of such…

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Ana Paula Dourado  (General Editor of Intertax)
The Contents of Intertax, Volume 48, Issue 11, 2020
October 20, 2020

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:   Qiang Cai, Luca Cerioni & Xiaorong (Sharron) Li, New Taxing Right…

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Tarun Jain , Shankey Agrawal  (BMR Legal)
Investment Treaties Interjecting Taxation’s Realm: The Latest in Vodafone’s India Saga
October 13, 2020

Last month witnessed the release of the operative part of the award of the Permanent Court of Arbitration (‘PCA’) in the dispute initiated by Vodafone’s Dutch entity against Government of India (‘GOI…

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Celine Martin  (Homburger)
Swiss Supreme Court Restates Principles of International Profit Allocation under Swiss Domestic Law
October 09, 2020

Swiss Domestic Law provides for an unlimited personal tax liability for companies if their registered offices or their effective place of management is located in Switzerland. This tax liability…

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Marcos Alvarez Suso  (Spanish Tax Administration)
The Relations Between the Tax Authorities and Non-established VAT Taxpayers in 2020. Are We Using 20th Century Rules for a 21st Century Digital World?
October 06, 2020

Marcos Álvarez Suso (Auditing Department of the Spanish Tax Authorities) The digital economy in the 21st century New business models associated to the so-called digital economy are blossoming in all…

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Jonathan Schwarz  (Temple Tax Chambers; King’s College London)
What is the purpose of a transaction?
October 06, 2020

Case law on thepurpose of transactions is starting to develop around the world. Is there a common pattern? Whether a financing structure was a “tax avoidance arrangement”  under  now repealed general…

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Giacomo Lindgren Zucchini  (Orebro University)
Composite Supplies: Some Reflections Regarding the Fundamental Identification of Single Supplies
September 28, 2020

The classification of transactions comprising several elements, features, and acts[1] is a complicated and prominent issue in the EU’s common system of VAT. It is also a popular topic for discussion…

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Vincent Ooi  (Singapore Management University)
Singapore’s Proposed Approach to Tackling Missing Trader Fraud
September 22, 2020

Missing Trader Fraud (“MTF”) is a problem that has plagued tax authorities around the world. It is a form of fraud by which syndicates make use of Value Added Tax (“VAT”) or Goods and Services Tax (“…

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Vikram Chand  (Tax Policy Center of the University of Lausanne, Switzerland) , Kinga Romanovska  (Tax Policy Center of the University of Lausanne, Switzerland)
Pillar II of the Digital Debate: Our View on the Approach Towards Blending and Substance Carve Outs to Determine Effective Tax Rates
September 18, 2020

1. Introduction The ability to stimulate economic activity and to attract foreign capital and investments through national tax policies has been known for many centuries. It was in the middle of the…

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