The article comments on the McCabe affair, a dual resident dispute regarding the application of the tie-breaker provision in article 4(2) of the Belgium-United Kingdom Tax Treaty and the lack of disclosure of the mutual agreement procedure in which the competent authorities settled the dispute...

In this installment of Emerging Economies, the first part of a series, Falcão and Michel focus on the rise of cryptocurrencies in developing countries and examine some of the tax policy challenges that come with it

The paper provides a number of comments on the OECD's public consultation document on 'Pillar One – Amount A: Draft Model Rules for Nexus and Revenue Sourcing.' The public consultation ran from 4 February 2022 to 18 February 2022. The nexus rules for a crucial part on how and to what extent...

The paper provides a number of comments on the Platform on Collaboration on Tax (PCT)'s draft Toolkit on Tax Treaty Negotiations. This submission is comprised of two parts. The first part discusses the terminology currently being employed in the PCT Toolkit on Tax Treaty negotiation, and...

The paper provides comments in response to the UN Tax Commitee's call for public comments on Tax Committee’s draft agenda for the membership for the session of 2021-2025. Four topics are presented which should be considered by the UN Tax Commitee. These items are:1. Source taxation of...

In this article, the author considers the implications of the recent decision of the French Conseil d’État (Supreme Administrative Court) regarding the recognition of a hidden agency permanent establishment that was used by the Irish company to sell online advertising services in France,...

International maritime shipping is an essential part of global business. Since the establishment of the current international tax regime in the 1920s, there has been a consensus that profits generated by this business are taxable only in the residence state – the state where the shipowners are...

On 8 December 2022, the European Commission (EC) released a proposal for a seventh amendment of Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC). The DAC8 proposal aims to broaden the scope of the current EU regime for automatic exchange of information (AEOI) on...

By design, the proposed crypto-asset reporting framework (CARF) will ensure that the bulk of crypto-asset users will see their relevant crypto transactions reported to their country of residence. But not all of them. The CARF does not catch transactions involving private wallets and fully...

The paper discusses the issues that ought to be taken into account by national tax administrations in developing international tax policy that is suitable to deal with cryptocurrency taxation going forward