Expert Corner

France
France: Recent Developments Impacting Inbound and Outbound Income Flows

France withholds tax on various types of income flows accruing to non-resident recipients. Like elsewhere, the applicable withholding tax may be impac...

Global
Approaching The Global Tax Pact from the Peripheral Economies’ Viewpoint

The Final Report on Action 1 was the greatest failure of the BEPS Plan; it did not conclusively respond to the direct taxation issues posed by the dig...

Global
The Crypto Series - Part II: The Background

The tax treatment of cryptocurrencies is a rapidly evolving debate with various countries, such as Spain, Portugal, India, and many others, adopting t...

Global
The Crypto Series - Part I: Taxation of Cryptocurrencies

Cryptocurrencies have become a headache for tax practitioners and tax auditors given their ambiguous nature and the technical expertise required to un...

European Union
The EU’s Unshell Directive

On 22 December 2021 the European Commission presented the proposal for a Council Directive no. COM(2021) 565 final laying down rules to prevent the mi...

Canada
Canada Top Court Blesses Treaty-Shopping Arrangement: The Alta Energy Decision

The Supreme Court of Canada (SCC) recently rendered its eagerly awaited decision in Canada v Alta Energy Luxembourg S.A.R.L., 2021 SCC 49 (Alta Energy...

Brazil
Brazilian Income Tax Reform and the Revaluation of Inbound Investment Structures

Tax reform agendas are not new in the Brazilian political environment. Several attempts — some broader and some narrower in scope — were made in the p...

Netherlands
The Netherlands: Withholding Tax on Royalty and Interest Payments

The Netherlands historically did not levy a withholding tax on outbound interest and royalty payments. The original rationale for this policy was that...

India
The Supreme Court Ventures into and Beyond the Taxability of ‘Royalty’ in Respect of Software Licensing Fees

The Hon’ble Supreme Court delivered its judgement in the case of [B:Engineering Analysis Centre of Excellence (P.) Ltd vs. Commissioner of Income tax[...

Denmark
Important 2020-21 Changes Impacting the Structuring of Business in and through Denmark

The tax scene in Denmark in 2020 and so far into 2021 has been marked by important developments which are bound to impact the structuring of internati...

European Union
EU VAT and E-Commerce from 1 July 2021 – The new rules explained

From 1 July 2021, Member States of the European Union [I:("EU Member States")] must comply with the VAT rules laid down by the VAT Directive[SUP:1], a...

Russia
Russia International Taxation - Year in Review and Look-Forward to 2021

2020 witnessed systemic developments in Russia's international tax framework, with the entry into force of MLI, the dismantling of a double tax treati...

Mexico
The Mexican Mandatory Disclosure Regime

In compliance with commitments assumed in the context of BEPS, Mexico adopted legislation requiring the mandatory disclosure of tax planning schemes (...

India
Tax Tribunal Extends Tax Treaty Restrictions on India's Dividend Distribution Tax: Implications for Non-Resident Investors

The purpose of tax treaties is to relieve the double taxation of income in the treaty partner countries. Relief from tax, however, is contingent upon...

Global
COVID-19 Crisis and EU VAT

On 30 January 2020, the World Health Organisation (WHO) declared the COVID-19 outbreak a public health emergency of international concern. On 11 March...