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Sergio André Rocha  (Rio de Janeiro State University, Sergio André Rocha Advocacia & Consultoria Tributária)
International Taxation, Epistemologies of the South, and Institutional Capacities: Transfer Pricing and the Universalization of the OECD Standards
May 07, 2018

Introduction As the General Reporter for the Subject 2 (The Future of Transfer Pricing) of the 2017 IFA Congress in Rio de Janeiro, I joined the plenary session on August 29 in a panel chaired by…

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Ben Kiekebeld  (General Editor EC Tax Review and tax adviser at Ernst & Young Belastingadviseurs LLP)
The Contents of EC Tax Review, Volume 27, Issue 2, 2018
May 07, 2018

We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Madeleine Merkx, John Gruson, Naomie Verbaan & Bart van der Doef,…

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Jonathan Schwarz  (Temple Tax Chambers; King’s College London)
Brexit: Transition brings tax-related controversy
April 26, 2018

There is only one legal certainty about Brexit. On 29 March 2019 EU law will cease to apply in the United Kingdom, as a result of the UK having given notice of withdrawal on 29 March 2017. This is…

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Piergiorgio Valente  (Crowe Valente/Valente Associati GEB Partners; Link Campus University, Rome)
Some remarks on the practical implications of the EU black list
April 24, 2018

The first common EU list of non cooperative tax jurisdictions – commonly referred as the EU black list – was released on 05 December 2017. It included seventeen offshore countries: American Samoa,…

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Cristiano Garbarini  (Partner, Gattai, Minoli, Agostinelli & Partners)
Six questions plus one about the proposed EU Directive on the taxation of a “significant digital presence”
April 20, 2018

On 21 March, just a few days after the publication of the (frankly not exciting) OECD report on the tax challenges of digitalization, the European Commission presented its own “package” on the…

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Mariette Cruywagen  (Partner/Director, Infinite Tax)
Indirect Tax across Africa: Can your business systems handle a VAT rate error
April 17, 2018

International VAT Principles Multi-Stage Tax Value-Added Tax (VAT) is designed to collect tax through a staged process. Each business in the supply chain takes part in the process of controlling and…

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Marta Villar Ezcurra  (CEU San Pablo University)
Who is leading the control of EU jurisdiction? The Achmea BV case and its impact on taxes and investments, e.g. in Spain
March 28, 2018

On 6 March 2018, the CJEU has issue its judgment on the case Achmea BV (C-284/16 here), that can impact many areas of the EU law, including tax matters. The Court states that “Articles 267 and 344…

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Frederik Boulogne  (Lubbers, Boer & Douma; VU University Amsterdam)
Implications of the CJEU’s Achmea decision (C-284/16) on tax treaty arbitration
March 26, 2018

On 6 March 2018 the Grand Chamber of the CJEU ruled in the Achmea decision (C-284/16) that the bilateral investment treaty (BIT) between The Netherlands and the Slovak Republic violated EU law…

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Jonathan Schwarz  (Temple Tax Chambers; King’s College London)
Exchange of Information: bumps in the road
March 21, 2018

Increased focus on taxation of cross-border situations involving both individuals and companies is one of the key features of the post-BEPS international tax environment. One central aspect of this…

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Alexander Haller  (WTS Munich, Germany) , Vikram Chand  (Tax Policy Center of the University of Lausanne, Switzerland)
Physical cash pooling in a negative interest rate environment
March 19, 2018

Introduction The financial crisis had made multinational enterprises (MNE) look inward for funding options, as external sources of capital were not readily available. Among various intra group-…

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