A considerable increase of transfer pricing disputes could be observed in Italy over the last decade.
Notwithstanding the rising trend of proceedings activated by the Tax Authorities and further…
If the UK leaves the EU, this would have immediate consequences for direct taxation.[1] We saw in the first post that the EU fundamental freedoms, EU provisions on State aid and EU directives and…
On 24 August 2016, the US Treasury Department issued a White Paper on “The European Commission’s Recent State Aid Investigations of Transfer Pricing Rules” (the “White Paper”), denouncing the…
The post-BEPS international tax scenario is in transition to a much more inter-nation equitable system, where the national tax base will be much better protected against erosion and profit-shifting…
A thought-provoking and insightful series of papers on taxpayer rights have just been published in the latest edition of The Tax Lawyer,[1] published by the American Bar Association Section of…
To withdraw from the European Union, the EU and the UK will need to negotiate a “divorce agreement” (see our first post here). Following this, a so-called Second Agreement could be negotiated between…
“Mirror, mirror, on the wall, who’s the fairest of them all?” – Brothers Grimm, “Snow White”
Where it all started
Tax evolved like many things in the world we experience today. Taxes were already…
This month I am going to present the first part (the justification) of a Congressional proposal that I am working upon for an academic article (I will appreciate any feedback). Thereafter, Haydon…
The divorce agreement and future gaps in UK law
Divorces are never easy. What will happen after the Brexit? Nobody knows yet. From a legal perspective, article 50 of the Treaty on European Union (…
Volume 44 (2016) issue 6/7 contains:
EDITORIAL:
Ana Paula DOURADO, 'The EU Anti Tax Avoidance Package: Moving Ahead of BEPS?'
ARTICLES:
Félix Daniel MARTINEZ LAGUNA, 'Institutional Hybrid…
