Measures to prevent the spread of coronavirus have impacted on every aspect of life. While the degree of enforced isolation and immobility varies from country to country, the basic elements remain…
The purpose of this short contribution is to shed some light on the discussion regarding an Uber drivers’ qualification – whether they should be considered employees or independent contractors. If…
Shareholder activities?
As mentioned by the 2017 Transfer Pricing Guidelines (TPG) of the OECD[1], one of the two main issues relating to the analysis of transfer pricing for intra-group services, is…
The decisions of European Court of Justice (CJEU) in the Vodafone and Tesco cases[1] were eagerly awaited by many interested in EU tax law. It was expected that the CJEU would answer the question…
Introduction
There is no divine truth about what the Arm’s Length Standard (ALS) actually means. Its content can only be determined by a decision, which can be reached by a court or by means of…
In the last years, we have witnessed many reforms to make the EU VAT system more consistent and business friendly. The Quick Fixes, which took effect on 1 January 2020, sought to harmonize some of…
Since 2013 the OECD has worked on forging a grand coalition (now 136 countries) it calls the “Inclusive Framework” around adopting the outcomes of the OECD’s Base Erosion and Profit Shifting (BEPS)…
Tax Administration Announces New Control Project
The Finnish Tax Administration has announced that it will be tackling arrangements to avoid withholding tax on dividends. According to the Tax…
1. Purpose of the blog
This contribution is a follow up to the previous contribution of the author. The objective is to address the tentative impact of the Pillar I debate on decentralized MNE…
The Canadian Federal Court of Appeal has upheld the Tax Court of Canada decision in Canada v. Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 (CanLII). The case is of some significance because the…
