The Commission's Communication on Business Taxation for the 21st century sets out reams of important tax policy announcements, whilst...
The Amsterdam Appeal Court decision which addresses this question deals with the double tax treaty between France and the Netherlands of...
In its decision in the Valueclick Case on 11 December 2020, the French Administrative Supreme Court ruled on the existence of a permanent...
The OECD has issued updated guidance on tax treaties and the impact of the COVID-19 pandemic which adopts broadly similar views on...
Simplification was a key theme of the public consultation on the OECD’s two-pillared international tax reform proposal. Zoe Andrews has...
The IMF's Annual Report for 2020 described the COVID-19 pandemic as a "crisis like no other", which has "created the worst recession...
The UK has effectively repealed DAC6 for the majority of cases.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...
The OECD's Impact Assessment presents its international tax reform proposal as the least worse-case scenario rather than a significant...
During OECD Tax Talks #17, Pascal Saint-Amans presented the Pillar One and Two Blueprints as a glass half-empty because no consensus has...
Amount A under Pillar One of the OECD’s two-pillared proposal for international tax reform would constitute a new taxing right for market...
Under the MLI (meaning the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS developed by the OECD)...
The Apple case is seen as raising the (very) hot topic of how a multinational group like Apple should be taxed in a modern, digital...
The UK’s Digital Services Tax (“DST”), which is a 2% levy on certain revenues derived from search engines, social media services and...
The paragraph of the OECD transfer pricing guidance on financial transactions dealing with parent guarantees is, in my view, incompatible...
The OECD has released the consultation document for its review of Country-by-Country Reporting which forms part of the standardised...
The OECD published its Pillar Two paper on the Global Anti-Base Erosion (GloBE) Proposal on Friday (Zoe Andrews' earlier post provides an...