11/30/2021 5:52:11 PM TAMD is upon us By Tanja Velling As part of the UK’s Autumn Budget, Chancellor Rishi Sunak announced that certain “tax administration and maintenance announcements” would...
3/17/2021 2:22:03 PM Is DAC6 a proportional measure? By Gloria Marín There is a question whether DAC6 might violate the principle of proportionality in Article 5(4) of the TEU. This principle requires that...
3/15/2021 12:00:00 AM Avoiding double DAC6 reporting: is the hierarchy in Article 8ab(3) of the DAC compatible with the freedom of establishment? By Gloria Marín The priority given, for the purpose of DAC6 reporting, to the Member State of residence over the Member State in which an intermediary...
3/12/2021 9:01:41 AM Penalties for failure to make a DAC6 report and the right to a fair trial By Gloria Marín Authorities may not impose penalties on individuals for refusing to provide information that may prove their criminal liability or...
3/10/2021 12:00:00 AM Does some Member States' implementation of the legal professional privilege exemption from DAC6 reporting infringe higher-ranking Union standards? By Gloria Marín The way in which some Member States have implemented DAC6 raises legitimate concerns on its validity and compatibility with...
3/8/2021 9:57:44 AM DAC6 and legal professional privilege - request for a preliminary ruling By Gloria Marín On 21 December 2020, the Belgian Constitutional Court (Grondwettelijk Hof) requested a preliminary ruling from the CJEU on the DAC 6...
1/7/2021 10:56:14 AM UK tax after IP completion day By Zoe Andrews Although the UK left the EU at 11pm on 31 January 2020, most people would not have noticed any change because the effect of the...
1/4/2021 12:00:00 AM DAC6: over (in the UK) before it’s begun? By Tanja Velling Dominic Robertson The UK has effectively repealed DAC6 for the majority of cases. With effect from 11 pm (UK time) on 31 December 2020 – the day before...
11/4/2020 2:32:08 PM Argentina: new reporting regime for domestic and international tax planning arrangements By Walter Keiniger The Argentine Tax Authority (AFIP) published a broadly drafted mandatory reporting regime for domestic and international tax planning...
6/25/2020 10:03:44 AM UK amongst those delaying DAC6 reporting deadlines By Zoe Andrews Rumours about a delay to the DAC6 filing dates have been tantalisingly rumbling on for a while now, as the commencement date of 1 July...
5/26/2020 9:19:07 AM How many hammers are needed to crack a nut? By Tanja Velling The ‘cum-ex scandal’ being the nut in question here. After a consortium of journalists uncovered schemes generating multiple refunds of...
11/1/2019 10:27:49 AM Dutch based in-house tax departments can be intermediaries under DAC6 By Maarten van der Weijden As the 31 December 2019 deadline for the implementation of DAC6 into the national legislation of EU Member States draws closer,...