The opinion of AG Emiliou in X BV v. the Dutch Ministry of Finance (C-585/22)
Dr. Svitlana Buriak (Loyens & Loeff / University of Amsterdam)[1]
Can a transaction entered into between two…
Part II. The (Toxic) Relationship of BO and GAAR in Light of the Husky Energy case.
“[T]he concept of beneficial ownership is a basic principle of income taxation: the beneficial owner of income is…
Part I. International treaty autonomous BO-GAAR relationship
“[T]he concept of beneficial ownership is a basic principle of income taxation: the beneficial owner of income is the person who should be…
Introduction
The present contribution aims at discussing two fundamental concepts often coming into play in the analysis of transactions between associated enterprises involving intangible property:…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:
Bruno Peeters, European Law Restrictions on Tax Authorities’ Use of…
Resolution 78/230 was approved by the United Nations General Assembly in December, 2023, creating a mandate for an ad-hoc committee inclusive of all UN member states to draft the terms of reference…
Highlights & Insights on European Taxation
Please find below a selection of articles published this month (March 2024) in Highlights & Insights on European Taxation, plus one freely…
In my previous blog I examined the Tax Court of Canada’s analysis of the meaning of beneficial ownership in tax treaties in Husky Energy Inc. v The King, 2023 TCC 167 in relation to stock or…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions:
Irma Mosquera Valderrama, Throughput Legitimacy of the Peer Review Process…
Introduction
The anti-profiteering law[1] under the Goods and Services Tax law (‘GST’) in India has been a subject matter of debate since the time GST was introduced. More than a hundred petitioners…
