Allocation issues: Transfer pricing and tax avoidance: just and reasonable solutions?
Article by Jonathan Schwarz (first published on KluwerTaxBlog) When the UK introduced its diverted profits tax, I was telephoned by a lawyer at the US Treasury.…
Category: Europe
GST Input Tax Credit: An Avoidable Controversy
By: Mukesh Butani (BMR Legal Advocates) We are pleased to mail you an Opinion piece as weekend long-read on the subject. The issue on claim…
What Is VAT Fraud?
Article by: Pawel Mikula, First published on KluwerTaxBlog One function of the law is to regulate human behaviour. An instrument to reach this goal is…
The Impact of the Coronavirus Pandemic Crisis on the VAT Framework
Article by: Korina Yiallourou – First published on KluwerTaxBlog In these unprecedented times of the Coronavirus pandemic, governments all around the world are striving to…
Income from immoveable property: Article 6 and royalty streams
Article by: Jonathan Schwarz, first published on KluwerTaxBlog Following the Supreme Court decision in Fowler v HMRC [2020] UKSC 22, the UK First-tier Tribunal has…
KrakVet Marek Batko (Case C-276/18): Against All Odds, VAT Double Taxation Exists in the EU
Article by: Edoardo Traversa, first published on KluwerTaxBlog International double taxation should be to European VAT harmonization what tropical temperatures should be to the polar…
DAC6 mandatory reporting to tax authorities of certain cross-border transactions
Article by A&L Goodbody (First published on Lexology) DAC6 is an EU Directive requiring the mandatory disclosure to tax authorities of certain cross-border arrangements. It…
What Does the MLI Actually Do for PEs?
Article by: Johann Müller – First published on KluwerTaxBlog Denmark accepted all MLI articles dealing with PEs, but what does that actually mean? Reading the…
The relationship between treaties and domestic anti-abuse provisions
Article by: Jonathan Schwarz (Temple Tax Chambers; King’s College London) – First published on KluwerTaxBlog In last month’s blog I promised to address the treaty…
Norway Supreme Court rules in favor of Shell subsidiary in transfer pricing dispute
By Michael Vorndran, Nord Advisory AS, Oslo, Norway On 28 May the Norwegian Supreme Court issued a ruling in a transfer pricing case between the Shell…