In this article, the author examines a recent decision by the Court of Appeal of Ghent (Belgium) regarding the qualification for tax treaty purposes of image rights payments derived by a non-resident professional football player, active in the Belgian first division

In this contribution to the Special Issue of European Taxation on treaty override the author outlines the complexity of the issue in the context of the rising importance of anti-avoidance, highlights the difference between treaty override and interpretation conflicts, provides a case study on...

As of 2013, Belgium has been levying a new tax called the "fairness tax". The tax consists in a separate corporate tax assessment of 5.15% levied on profit distributions by Belgian companies or branches that do not realize taxable profits because of the offsetting of previous losses or the...

This article examines the decision in Austria v. Germany (Case C-648/15), which was submitted to the ECJ pursuant to the Austria–Germany Income and Capital Tax Treaty (2000). The author examines (1) the EU law aspects of the decision, in particular the Court’s jurisdiction to hear tax treaty...

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 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

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 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...