In my International Taxation class tomorrow (October 10th) we are going to discuss the OECD's “Unified Approach” released a day earlier on October 9, 2019. Given the keen interest generated by…
India recently notified a Protocol that amends the India-China tax treaty and incorporates some of the OECD recommendations put forth as part of its BEPS project. The changes would apply from the…
Introduction
Last fortnight, India by way of a Presidential Ordinance unexpectedly unveiled a new corporate tax rate structure. Given that the annual Union Budget exercise was presented in July, the…
The General Court of the European Union has issued two awaited rulings in the Starbucks[1] and Fiat[2] cases. The length and the depth of the analysis made by the judges of the General Court should…
While earthlings are grappling with taxation in a digitalised world, a new and important frontier has been opening up somewhat less observed. Commercial exploitation of space has become commonplace…
In many member states’ tax law, mutual investment funds are relieved from double taxation, i.e. proceeds from investments are taxed only once even though they are earned on two levels: first at the…
William Byrnes, Texas A&M University School of Law* (33-page draft research available on SSRN)
Howdy! Earlier today the General Court of the European Court of Justice (EGC) sided with Starbucks…
On 10 September Wolters Kluwer organized an interesting discussion on Permanent Establishments. The discussion was led by 3 panelists, Tamara Schwärzler (PwC Switzerland); Arvid A. Skaar (Norwegian…
Nothing changed but the change
Despite several changes were introduced to Chapter I and Chapter VI of the 2017 OECD Guidelines on intangibles in accordance with Actions 8-10 BEPS Final Reports to…
Not the Hungarian Constitutional Court but maybe AG Kokott in her forthcoming opinion in the Google Ireland case…
Optimistically speaking, the Hungarian Advertisement Tax contributes to a large…
