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December 22, 2019

OK so I’m lying on the couch getting over a spot of flu and taking in a YouTube recording of Bach’s Christmas Oratorio on my iPhone.

Before we’re a decent time into the 2½ hour long recording I get interrupted by an ‘online ad’. I can skip it, so not a major downer on m...

May 9, 2019

  1. Mandatory and binding arbitration as well as enhanced dispute prevention measures must accompany any change to market nexus and profit allocation rules.
     

  2. Any solution to market allocation of taxing rights should apply equally to losses.
     

  3. Wait for impl...

February 25, 2019

Anyone who thought the EU’s anti-tax avoidance directive was going to streamline 28 Member States’ different rules into a single harmonious EU whole is either a supreme optimist, doesn’t work in tax, or does work for the European Commission.

At least that’s my conclusio...

February 4, 2019

Nine takeaways based on my article on the European Commission’s state aid tax case against the hamburger giant: Tax Notes International, February 4, 2019.

If you want to check out the Commission’s decisions, here are the links to the initial and final versions.

1. The Co...

August 8, 2018

With less than six months to go before ATAD 1 starts to kick in, now may be a good time to test your knowledge of what the EU’s anti-tax avoidance directive has in store. Here's my take on the following 10 questions.

1) A company with net interest expense of EUR4m canno...

June 11, 2018

After the European Court’s decision in the Hornbach case, EU groups may feel a lot more comfortable about extending soft loans, or giving fee-free guarantees for external loans to their ailing subsidiaries. If this happens to result in a lower tax bill for the group, l...

May 6, 2018

Takeways from my Tax Notes International column 'A Certain Tax Position', May 7, 2018

  • Domestic Member State anti-avoidance tax rules may be struck down if they infringe EU laws or principles, like the freedom of establishment

  • Conversely, domestic laws that pote...

February 21, 2018

It would be a mistake to assume that the digital tax measures being discussed at OECD and EU level will be limited to particular business sectors. After all, the digital economy is increasingly becoming the economy itself, as the OECD and many others have pointed out....

January 20, 2018

  • Ultimate aim for information exchange seems to be implementation of CRS, CBCR, rulings exchange, and exchange on request

  • Dates and periods are vague, but in general grey listed jurisdictions have been given an extra year to comply

  • There are various ‘escap...

November 27, 2017

Both House and Senate tax reform drafts include measures that are popularly being referred to as a US ‘patent box’. A patent box (also: innovation box; IP box) is in essence a special low tax rate applied to income generated by certain types of IP. As such, patent boxe...

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February 4, 2019

August 8, 2018

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