8/18/2022 9:43:05 AM UK advances multinational top-up tax despite mostly a lack of progress elsewhere By Zoe Andrews The US has finally passed some tax legislation in the form of the Inflation Reduction Act. But before you get too excited, it does not...
1/20/2022 4:34:07 PM A question of substance – a first look at the EU Commission's "Unshell Proposal" By Isabella Zimmerl Two recent trends in international taxation – an increase in taxpayers' obligations to document and share information with tax...
12/2/2021 3:33:04 PM Public CbCR has arrived in the EU By Tanja Velling The EU's directive on public country-by-country reporting was published in the Official Journal on 1 December 2021 to take effect on the...
6/16/2021 10:34:33 AM Public CbCR to be implemented in the EU By Tanja Velling Public country-by-country reporting is set to be implemented across the EU (including for non-EU headquartered groups) by early 2023 to...
5/19/2021 10:26:18 AM From CCCTB to BEFIT: the European Commission's plan to future-proof taxation By Tanja Velling The Commission's Communication on Business Taxation for the 21st century sets out reams of important tax policy announcements, whilst...
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...
1/22/2021 12:00:00 AM Precautionary measures: who gets to decide? By Tanja Velling In Heavyinstall, the CJEU decided that, where one EU Member State requests that another takes precautionary measures, such as seizing...
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...
10/27/2020 10:06:03 AM European Commission initiates review of VAT rules for financial and insurance services By Darya Budova Violeta Pina On 22 October 2020, the European Commission published an inception impact assessment for the review of the VAT rules for financial and...
7/29/2020 2:52:04 PM Dutch courts embrace Danish conduit cases By Maarten van der Weijden Tax authorities in Europe are racing to apply the principles set forth by the European Court of Justice in the Danish conduit cases to...
6/26/2020 9:52:21 AM Cross-border recovery of tax debts through set-off By Tanja Velling If one Member State requests assistance from another Member State in respect of the recovery of a debt under the Mutual Assistance...
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...