On 20 May 2022, the French Conseil d’État issued a significant decision in the Planet case addressing treaty-based withholding tax relief when royalties are paid through
third-state intermediaries. The case concerned Article 12(2) of the 1979 France–New Zealand Tax Treaty (FRA/NZ Treaty) involving a French company paying royalties [...]
The emergence of the digital economy has made user data a valuable asset at commercial levels. This commercial appeal translates into economic benefits for those digital companies
that manage to collect, select, and sell it. Data mining and its business (with the actual international tax regulation and awaiting international agreements for [...]
The taxation of cross-border transactions is predominantly governed by the Organization for Economic Co-operation and Development (OECD) Model Convention that South Africa
and other jurisdictions have adopted through a network of double tax conventions (DTCs). [...]
While the ‘foreign subsidy’ concept is among the key concepts delineating the scope of the Foreign Subsidies Regulation (FSR), the exact interpretation of its various cumulative
elements is unclear. The preamble of the FSR suggests that inspiration should be drawn from EU State aid law, while the wording employed in the definition itself [...]
