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First-Mover Disadvantage? Challenges to Being Tax Resident in an Early Pillar Two Jurisdiction

The OECD envisioned a coordinated rollout of Pillar Two, its model of interlocking rules to establish a global minimum corporate tax rate. However, the staggered implementation taking place among participating...more

EU Court of Justice Faults European Commission for Expansive Interpretation of State Aid in Tax Rulings

On November 8, 2022, the Court of Justice of the European Union (CJEU), overturning the first instance EU General Court (General Court), annulled the European Commission’s (EC’s) decision that a Luxembourg tax ruling on...more

Plus Ça Change ... Reframing the Tax Influences of the European Union

Takeaways - While the Trade and Cooperation Agreement (TCA) includes new commitments by the parties on tax, certain EU-derived tax rules will remain relevant in the UK. - That is actually a good thing in one respect: UK...more

European Commission Presents ‘Fair Taxation of the Digital Economy’ Package

On March 21, 2018, the European Commission released a draft legislative package for “fair taxation of the digital economy,” which would establish new tax rules for digital business activities within the European Union. This...more

International Taxation in the Digital Era: The Rapidly Evolving European Perspective

Europe’s politicians worry that international tax rules have not kept pace with the digital economy and too easily allow multinationals to organize their global operations to minimize net taxable profits in high-tax European...more

"Business Tax Reform All but Certain in US, Europe"

United States - The prospects for business tax reform in the United States were greatly enhanced by the 2016 election results. Reform under Republicans, who control both the White House and Congress, could dramatically...more

Brexit: An Opportunity to Readjust UK Tax Policy?

The U.K. government mantra has for a number of years been: "Britain is open for business." This has been reflected in a number of areas relevant to U.K. domestic and foreign tax policy, including in a gradual reduction of the...more

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