The paper discusses the European Commission’s tax policy agenda in business income taxation and the ongoing legislative initiatives in this regard as per early 2022. The focus is on the Commission Communication titled ‘Business Taxation for the 21st Century’ of 18 May 2021 and the...

On 2 February 2023, the OECD/G20 Inclusive Framework published its first round of technical guidance for governments to assist them in the domestic implementation of the upcoming global 15% minimum business income taxation framework (Pillar Two). The authors discuss the guidance to the operation...

This paper elaborates on the tax policy responses in the area of direct taxation that are currently on the table at both the OECD and EU levels. The digital economy cannot be seen in isolation from the rest of the economy; it is the overall economy that is becoming increasingly digitalised. As...

The OECD is holding public consultations on 13 and 14 March 2019 on the challenges facing countries' corporate tax systems as a result of the ever-increasing digitalisation of the economy. As part of these consultations, a document listing the problems at stake and suggestions for possible...

This paper elaborates on current and emerging issues involving the operation of the concept of permanent establishment (PE) in the national tax system and double tax treaty system of the Netherlands. The paper was written as a contribution (country report) to the seminar “New Trends in the...

Although we live in an age in which everything and everyone is ‘online connected', countries' profit taxation systems are still based on an economic reality of around a century ago. And that creates tension. The problems this tension causes are particularly evident in the case of profits...

Traditionally, countries impose their corporation tax on an entity-by-entity rather than a group-wide basis. As the taxability of entities, tax bases, and tax rates vary from one country to another, these differences give rise to mismatches, leading to double taxation, but also to non-or almost...

The current international corporate tax regime for taxing the business proceeds of firms operates arbitrarily. The aggregates of the nation states' international corporate tax systems seem to distort a global efficient allocation of resources. The model is ill-suited to current market realities....

Winds of change have been blowing through the world of international company taxation, with company tax planning and country tax competition increasingly attracting questions from the general public, the media, politics and academia. The most systemic corporate tax reform proposal in the EU so...

This paper elaborates on the provision on tax abuse in the EU's Anti Tax Avoidance Directive (‘ATAD'): the general anti-abuse rule (‘GAAR'). The GAAR allows EU Member States to disregard for company tax purposes any non-genuine arrangements that have been put in place to defeat the object or...