Since the OECD started conceiving and implementing the BEPS project, the major argumentation in favour of the new policies is mainly based on the refrain that everybody should pay their “fair share”…
One of the fascinating features of EU law is that no matter how well-established its classics may be, they are revisited over and over again. If you thought you had seen it all about preliminary…
Taxation of the digital economy remains fixed in the first position of the international tax charts, with the discussions focusing lately on the so-called Amazon tax considered to be introduced in…
Introduction
Recently captive insurance arrangements have been scrutinized all over the world by tax authorities as they are believed to be vehicles that encourage profit shifting. The OECD, in the…
The Tax Court of Canada decision in Alta Energy Luxembourg S.A.R.L. v. The Queen, 2018 TCC 152 (CanLII) on August 22, 2018 may provide useful pointers to the meaning and application of the PPT found…
The idea for this article came to me after I read a piece published by the International Tax Review with the title "Mexico confirms that US may qualify as a preferential tax regime in light of the…
I am delighted to inform you that the latest issue (Issue 10) of the journal is available online.
My editorial focuses on the recently published OECD Financial Transactions Discussion Draft, Ruth…
Some recent decisions of the CJEU (Eqiom, C-6/16 of 7 September 2017, and Deister Holding and Juhler Holding, joint cases C-504/16 and C-613/16 of 20 December 2017) and the conclusions of AG Kokott…
The Marks & Spencer case (C-446/03), in which the Grand Chamber of the Court of Justice of the European Union rendered its decision that final losses incurred by its non-resident subsidiary can…
According to the OECD’s work “The Role and Design of Net Wealth Taxes in the OECD” (published on April 12, 2018, available here), very few OECD countries still apply net wealth taxes to individuals:…
