The OECD proposal for a global minimum tax (GloBE) is designed in a manner that could be conflictive with investment treaties. This tension is even more severe in the context
of its adoption in the European Union through Directive (EU) 2022/2523 as EU Law prima facie supersedes any other international law obligation adopted by Member States. [...]
This article uses recent expenditure survey data to investigate how indirect taxes are paid across the Brazilian population. It applies a novel approach to estimate the effective
tax rate by computing the specific cumulative taxes levied on thousands of items available in the data set. [...]
The article analyses the EU and European Economic Area (EEA) Member States’ leeway under the state aid rules in Article 107 Treaty on the Functioning of the European Union
(TFEU) and Article 61 EEA Agreement regarding the use of tax incentives to promote the green transition for which they currently have a more significant amount of [...]
The cryptocurrencies that are an integrated part of blockchains have led to creating enormous value and wealth that attract increasing attention from investors and governments.
The sophistication and anonymity of crypto assets create significant challenges for tax administrations as the current tax rules and guidelines in relation to them [...]
The role of value creation when allocating taxing rights has been a central topic of debate since its introduction in the OECD Base Erosion and Profit Shifting (‘BEPS’)
Project. This discussion has led to disagreements and uncertainties regarding the meaning and function of the term. [...]
In recent years, the debate surrounding the proposal of a robot tax as a response to the adverse impacts of accelerated automation on human labour has gained significant traction.
Its increasingly skill-biased substitution with automation processes is assumed to result in diminishing labour income tax revenues and simultaneously increasing [...]
The article investigates a specific aspect of the proposal for an EU directive on transfer pricing: the arm’s length range. The matter is addressed in Article 12 of the proposal
which states that only the interquartile range of values resulting from the benchmark can be considered as being at arm’s length. [...]
The Court of Justice of the European Union (CJEU) ruling in Case C-621/22 provides certainty regarding the possibility to qualifying commercial interests as legitimate interests
under Article 6(1)(f) of the General Data Protection Regulation (GDPR). The CJEU enumerates the criteria that must be fulfilled and confirms that direct marketing [...]
