The Debate
What makes a tax system competitive? How can countries multiply the competitiveness of the existing system?
These question-marks are attracting substantial research by today’s policy…
The judgements of the CJEU in N Luxembourg 1 v Skatteministeriet (Case C-115/16) and joined cases and in T Danmark (Case C-116/16) and another joined case, on 26 February 2019, once again addressed…
1. Purpose of the blog
Intra-group guarantees are usually used by companies within the same multinational enterprise to obtain beneficial conditions for funding arrangements. For instance, lower…
The classic issue of dynamic versus static interpretation of tax treaties arises again. Not only is this a hot topic in the international tax arena, but it is also a permanent pain in the Spanish…
This second and last part of the contribution concentrates on the present and future of artificial intelligence (AI)[1] and tax law. Let us see if AI can be happily married with tax law in order to…
According to recent research’s prediction,[1] global GDP could be up to 14% higher in 2030 as a result of various artificial intelligence (AI)[2] applications, which is the equivalent of an…
According to an undisclosed policy paper that is currently circulated within the OECD, the German government is promoting an internationally coordinated reform of corporate taxation. Specifically,…
As we approach the halfway mark between the 2018 IFA conference in Seoul and the 2019 one in London, I want to clear up some issues around “Business” as in stakeholders in tax discussions.…
The Italian Stability Law for 2019 finally approved on 30 December 2018 has introduced a new art. 24-ter in the Income Tax Act (ITA). It includes a substitute tax of 7%, in lieu of ordinary taxation…
For thousands of years the human species was constrained to limit its activities and creativity in the planetary space. Today, the Digital Revolution has opened a new space: the cyber-space, removing…