Europe

International Taxation of E-commerce Business Income

Article by: Dr. Dennis Ndonga (Lecturer, Murdoch University Australia) The rapid growth of cross-border e-commerce has challenged the existing international tax principles that are structured around national boundaries and State sovereignty. Most tax regimes generally assert jurisdiction to tax business income based on the principles of residence-based and source-based taxation. The residence-based system imposes taxes […]

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Double Tax Treaties: An Introduction

Paper by: Reuven S. Avi-Yonah The existing network of over 2,500 bilateral double tax treaties (DTTs) represents an important part of international law. The current DTTs are all based on two models, the OECDThe Organisation for Economic Co-operation and Development (OECD) is an international organisation comprising 38 member countries, established to foster economic growth, trade,

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Tax Controversy – Impact Of ‘Disruptive’ Digitalization Processes on Taxpayers

In a world that is moving at a fast pace in the light of the “disruptive” digitalization processes happening at the moment, it is essential for taxpayers to be aware of their rights and of the balance of power existing between them and the tax authorities (“TAs”).  In this webinar we will discuss rulings from the

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Zimmer Ltd. vs. Germany (2018): Implications for International Taxation and Transfer Pricing

Explore our detailed analysis of the Zimmer Ltd. vs. Germany (2018) case. Learn how this ECJ judgment impacts the definition of Permanent Establishment and international tax compliance.

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Cadbury Schweppes vs UK: EU Ruling on Freedom of Establishment and Tax Avoidance

The Cadbury Schweppes case is a seminal ruling in the context of the European Union’s freedom of establishment and the limitations on Member States’ tax authorities to impose tax measures on Controlled Foreign Companies (CFCs).

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