In January 2008 the Czech Republic introduced the environmental taxation based on the directive 2003/96/EC, restructuring the Community framework for the taxation of energy products and electricity. Environmental taxes are imposed on electricity, solid fuels and natural gas. This paper discusses...

Canadian National Report prepared for the Vienna University of Economics and Business, Conference on tax secrecy and transparency, Rust, Austria, July, 2012. The aim of the project is to assess how different countries regard the treatment of tax information and tax secrecy. Topics include the...

This article examines the compatibility of the OECD's proposed rules on GloBE (pillar II) with EU law, covering both primary law and secondary law. In addition, it discusses the amendments required by the implementation of this initiative within the internal market. In what concerns...

This note reviews May 2019 OECD framework agreement report, “OECD/G20 Inclusive Framework on BEPS: Progress Report July 2018-May 2019” on international taxation of the ‘digital economy'. The core conclusions of the review are:1. The framework agreement proposals to-date represent complex,...

When a debtor goes bankrupt and limited assets have to be divided between competing creditors, should unpaid taxes owed to the government be paid before the debts owed to other creditors? This Article defends the notion that some tax debts should be awarded priority. Insofar as bankruptcy...

I.R.C. § 6323, which governs how the federal tax lien ranks against the interests of the taxpayer's other creditors, subordinates the tax lien to the claims of other creditors in various ways. Tax lien subordination is commonly justified on the grounds that it enhances taxpayer asset value,...

This Study contains the final version of the document elaborated by the IBFD Task Force on the Digital Economy as a submission to the European Commission in the framework of its 2021 Public Consultation on the possible introduction of an EU digital levy. Based on a reconstruction of the...

This article is a commentary on the decision of the Court of Justice of the European Union on the Vodafone case, C-74/78 on progressive turnover taxes.In our view, the Court’s decision provides clarifications for ascertaining the compatibility of domestic turnover taxes with the fundamental...

This study is focused on the tax measures that have been enacted in Portugal, following the health and economic crisis created by the SARS-CoV-2/COVID-19 pandemic.First, it aims at comprehensively characterizing the measures enacted, structuring them by thematic clusters, enabling the reader to...

In the past year, a number of new financial transactions (such as the Fantex, Upstart and Pave transactions) have emerged that allow individuals to raise funds by offering a percentage interest in their future earnings. Unlike traditional lending arrangements, these structures essentially enable...