With effect from 2024, the Italian Government established a new single Special Economic Zone for the South of Italy (hereinafter the “Single SEZ”, in ...
Outline of the Article The Indian Supreme Court delivered a landmark ruling which impacts multinational entities from countries such as France, Switze...
The case and the decisionOn 6 June 2023, the Italian Supreme Court decided the case of a Swiss-resident company seeking the refund of the Italian with...
The Danish Supreme Court has now given its final judgments in the so-called "Danish Cases". To some degree, the determination of who is &quo...
On 9 January 2023, the Danish Supreme Court gave final judgements in the first two of the so-called "Danish Cases" to reach the Court. Rulin...
On 8 December 2022, the European Commission1 launched a package of proposals aimed at – as the Commission expressed it – “adapting the EU VAT system t...
France withholds tax on various types of income flows accruing to non-resident recipients. Like elsewhere, the applicable withholding tax may be impac...
A combination of factors is putting pressure on the Brazilian government to quickly conclude the drafting of a bill with the new Brazilian transfer pr...
France withholds tax on various types of income flows accruing to non-resident recipients. Like elsewhere, the applicable withholding tax may be impac...
The Final Report on Action 1 was the greatest failure of the BEPS Plan; it did not conclusively respond to the direct taxation issues posed by the dig...
The tax treatment of cryptocurrencies is a rapidly evolving debate with various countries, such as Spain, Portugal, India, and many others, adopting t...
Cryptocurrencies have become a headache for tax practitioners and tax auditors given their ambiguous nature and the technical expertise required to un...
On 22 December 2021 the European Commission presented the proposal for a Council Directive no. COM(2021) 565 final laying down rules to prevent the mi...
The Supreme Court of Canada (SCC) recently rendered its eagerly awaited decision in Canada v Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 (Alta Energy...
Tax reform agendas are not new in the Brazilian political environment. Several attempts — some broader and some narrower in scope — were made in the p...
The Netherlands historically did not levy a withholding tax on outbound interest and royalty payments. The original rationale for this policy was that...
The Hon’ble Supreme Court delivered its judgement in the case of [B:Engineering Analysis Centre of Excellence (P.) Ltd vs. Commissioner of Income tax[...
The tax scene in Denmark in 2020 and so far into 2021 has been marked by important developments which are bound to impact the structuring of internati...
From 1 July 2021, Member States of the European Union [I:("EU Member States")] must comply with the VAT rules laid down by the VAT Directive[SUP:1], a...
2020 witnessed systemic developments in Russia's international tax framework, with the entry into force of MLI, the dismantling of a double tax treati...
In compliance with commitments assumed in the context of BEPS, Mexico adopted legislation requiring the mandatory disclosure of tax planning schemes (...
The purpose of tax treaties is to relieve the double taxation of income in the treaty partner countries. Relief from tax, however, is contingent upon ...
On 30 January 2020, the World Health Organisation (WHO) declared the COVID-19 outbreak a public health emergency of international concern. On 11 March...