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Piergiorgio Valente  (Crowe Valente/Valente Associati GEB Partners; Link Campus University, Rome)
Competitive Taxation and Tax Competition: The Winner Takes it All?
March 04, 2019

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…

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Jonathan Schwarz  (Temple Tax Chambers; King’s College London)
Beneficial ownership: CJEU Landmark ruling
February 27, 2019

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…

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Vera Averyanova , Vikram Chand  (Tax Policy Center of the University of Lausanne, Switzerland)
Applying the Arm’s Length Principle to Intra-Group Financial Guarantees in light of the OECDs Draft guidance on Financial Transactions
February 14, 2019

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…

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Antonio Barba de Alba  (Partner Cuatrecasas Madrid) , Diego Arribas  (Tax Associate Cuatrecasas)
Spanish Supreme Court to Settle on Dynamic Interpretation of Tax Treaties
February 04, 2019

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…

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Błażej Kuźniacki  ( PwC Netherlands, Lazarski University and Singapore Management University)
The Marriage of Artificial Intelligence and Tax Law: (II) Presence & Future
January 25, 2019

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…

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Błażej Kuźniacki  ( PwC Netherlands, Lazarski University and Singapore Management University)
The Marriage of Artificial Intelligence and Tax Law: (I) Past & Present
January 23, 2019

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…

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Johannes Becker , Joachim Englisch  (University of Muenster)
The German Proposal for an Effective Minimum Tax on MNE Profits
January 17, 2019

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,…

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Johann Müller  (International tax professional)
Who is “Business”? Notes for the 2019 IFA Congress in London
January 15, 2019

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.…

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Giorgio Beretta  (Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Lund University)
Italy: A Country for Tax-Savvy Old Men?
January 11, 2019

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…

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Piergiorgio Valente  (Crowe Valente/Valente Associati GEB Partners; Link Campus University, Rome)
Cyber-Diplomacy and Digital: Some Legal and Economic Aspects
January 08, 2019

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…

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