The global crisis provoked by the Covid-19 disease has affected several spheres of our lives. Apart from health, the biggest impact has been felt in the reduction of production and consumption,…
The VAT treatment of the issue, acquisition, holding and sale of shares has become a rather complicated affair over the last thirty years. The case law of the Court of Justice of the European Union (…
Duplicate activities?
Duplicate services are defined in the 2017 Transfer Pricing Guidelines (TPG) of the OECD as “activities undertaken by one group member that merely duplicate a service that…
Denmark accepted all MLI articles dealing with PEs, but what does that actually mean? Reading the MLI itself leaves one somewhat bewildered, being thrown back and forth between a variety of articles…
In last month’s blog I promised to address the treaty aspects of Davies and Others v HMRC [2020] UKUT 67 (TCC). The case concerned UK resident individuals who each took out a life insurance policy…
A subsidiary can (also) be a fixed establishment (FE) of its parent company under European (EU) VAT, after all. This is the most immediate conclusion as it emerges from the much-awaited decision by…
Council Directive (EU) 2018/822 (generally known as DAC 6) expressly provides for reporting obligations concerning cross-border arrangements that present an indication of a potential risk of tax…
The OECD’s BEPS 2.0 project is currently navigating turbulent waters partly because of the unexpected Covid19 crisis and its impact on state budgets and the need for additional revenues, and partly…
We have all become familiar with the expression in the PPT set out in article 7(1) of the MLI and article 29(9) of the 2017 OECD Model where “obtaining that benefit was one of the principal purposes…
Purpose of the blog
The purpose of the blog, which is slightly futuristic, is to discuss whether countries will still compete with one another to attract activities in their jurisdiction post-Pillar…
