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See detailDAC6 and the Challenges Arising from Its Disclosure Obligation
Bianco, Arthur UL

in EC Tax Review (2021), 30(1), 8-23

Directive 2018/822 (‘DAC6’) aims at ensuring the exchange of information between Member States of potentially tax-aggressive arrangements. To do so, the European legislator has entrusted intermediaries ... [more ▼]

Directive 2018/822 (‘DAC6’) aims at ensuring the exchange of information between Member States of potentially tax-aggressive arrangements. To do so, the European legislator has entrusted intermediaries across the European Union with the task of gathering and reporting a number of potentially aggressive tax arrangements to improve tax transparency and stifle tax avoidance. Unfortunately, a closer analysis of the text has revealed multiple issues that may threaten the well-functioning of the system and could impede the action of the intermediaries. From missing definitions and a lack of guidance to new concepts in dire need of proper interpretation, intermediaries are left with a daunting task to tackle. Risks of delays and over-disclosure, arising from the inconsistencies and uncertainties left by the text of the instrument, may not only undermine the effectiveness of the reporting obligation, but also that of the rest of the system altogether. [less ▲]

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See detailThe Reflection of Data-Driven Value Creation in the 2018 OECD and EU Proposals
Sinnig, Julia UL

in EC Tax Review (2018), 27(6), 325-334

Is the current corporate tax system fit for the digitalized economy? The 2018 interim report of the OECD and the proposals of the European Commission on the introduction of significant digital presence ... [more ▼]

Is the current corporate tax system fit for the digitalized economy? The 2018 interim report of the OECD and the proposals of the European Commission on the introduction of significant digital presence and a digital services tax give new insights into policymakers’ perception of ‘value creation’ and income generation in digitalized business models. Although the right way to tax digitalized business models seems disputed with regard to the diverging outcomes of the OECD’s and European Commission’s work so far, it seems to be of common understanding that user data are susceptible of establishing a taxable nexus. In a first step, this article aims at analysing how the collection and processing of user data may create such genuine link between an income generating activity and a state territory enabling this state to exercise its taxing right. In that respect, the concept of value creation, a driving concept in the discussion on how to tax digitalized businesses, is critically reviewed and an attempt to understand its real meaning is presented. In a second step, the article analyses to which extent the long- and short-term proposals of the European Commission reflect such data-driven (taxable) value creation, critically highlighting their main characteristics and flaws. [less ▲]

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See detailThe Proposal for an EU Anti-Avoidance Directive: Some Preliminary Thoughts
Navarro, Aitor; Parada, Leopoldo; Schwarz, Paloma Natascha UL

in EC Tax Review (2016)

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See detailTax selectivity in State aid review: A debatable case practice’
Micheau, Claire UL

in EC Tax Review (2008), (17), 276-284

Detailed reference viewed: 132 (0 UL)