This article is the last of a series of three posts dealing with non-chargeable intra group services: Shareholder Activities, Duplicate Activities and Incidental Benefits. This post will specifically…
In Part 1, we discussed in a first step the ground barrier for taxing data in the context of international taxation: a proper definition of data. In a second step, we showed you which negative…
For international tax law, it is of central importance how to locate, value & control the increasingly digital cross-border supply and service relationships within a multinational enterprise (MNE…
A couple of days ago, in the last weekly session of the Indiana-Leeds Summer Tax Workshop, I attended the presentation of a fascinating paper by Steven A. Dean (A Constitutional Moment in Cross-…
One function of the law is to regulate human behaviour. An instrument to reach this goal is to impose sanctions for undesirable behaviour on persons who are responsible for inadmissible acts. It goes…
Introduction
Except for the unprecedented health crisis, the COVID-19 spread has generated the biggest economic and financial shock of the century across markets and cross-borders.[1] The preventive…
In these unprecedented times of the Coronavirus pandemic, governments all around the world are striving to sustain their health systems while managing, as far as possible, the economic damages caused…
Inspiration, purpose and the context of this contribution
In the article “The PPT in Post-BEPS Tax Treaty Law: It Is a GAAR but Just a GAAR!”, Professor Robert Danon convincingly demonstrated that “…
Composite supplies are one of the most commonly debated issues under European VAT (EU VAT). Despite its unquestionable relevance as a topic, neither Directive 2006/112/EC (the VAT Directive) nor…
The importance of digitalization has been demonstrated especially at this time of the COVID-19 disease pandemic. State and local institutions, as well as entrepreneurs, were in fact able to maintain…
