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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

Tax Law Struggles To Keep Pace With the Proliferation of Cryptocurrency

Takeaways - The technical architecture of various cryptocurrencies makes it difficult to bring them within existing tax rules, even those designed to deal more generally with the digital marketplace. The U.S., U.K. and...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

Three Years, Two Pillars and One New Headache for Investment Funds

Fund sponsors, investment advisors and other financial market participants would be forgiven for not concerning themselves with tax initiatives originally targeted at the digital economy. However, with the latest technical...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

"OECD Outlines Plans to Prevent Double-Tax Treaty Abuse"

On March 14, 2014, the Organisation for Economic Co-operation and Development (OECD) published a discussion draft report on preventing double-tax treaty abuse (the Treaty Report). The OECD supplemented this release on March...more

"OECD Releases Global Standard for Automatic Exchange of FATCA-Type Information"

As part of a push for greater transparency, the Organization for Economic Cooperation and Development (OECD) released on February 13, 2014, a Common Reporting Standard (CRS) for Automatic Exchange of Financial Account...more

"Base Erosion and Profit Shifting: Key UK Issues"

Six months have elapsed since the Organisation for Economic Co-operation and Development (OECD) released its 15-point action plan to address Base Erosion and Profit Shifting (BEPS). During this time, OECD has been working...more

"International Taxation – OECD Reboot for the 21st Century"

Introduction - Following on its February 2013 report on Addressing Base Erosion and Profit Shifting (BEPS), the Organisation for Economic Co-operation and Development (OECD) has now released an ambitious action plan...more

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