[{"id":2003536,"description":"On December 30th of last year, the Indian Income Tax Appellate Tribunal was the first “quasi judicial institution” to apply the PPT to a treaty-shopping arrangement.[1] The case concerned a dispute between a Luxembourg-based holding company, SC Lowy, and the Indian tax authorities. Facts of the case The Luxembourg holding company, SC Lowy, is owned... Continue","source":"Kluwer International Tax Blog","pubDate":"Mon, 24 Mar 2025 10:22:04 +0100","titre":"Lowy: the first PPT-case","url":"https://kluwertaxblog.com/2025/03/24/lowy-the-first-ppt-case/"},{"pubDate":"Wed, 19 Feb 2025 10:29:54 +0100","titre":"The U.S. pushback on minimum corporate tax rates may test the limits of bilateral tax treaties with EU Member States","url":"https://kluwertaxblog.com/2025/02/18/the-u-s-pushback-on-minimum-corporate-tax-rates-may-test-the-limits-of-bilateral-tax-treaties-with-eu-member-states/","source":"Kluwer International Tax Blog","id":1925272,"description":"*This post was first published on the website of Maastricht University*   In recent weeks the tax world gave a lot of attention to how President Trump blew up some serious advancements in international tax law, long in the making. One of those advancements was the introduction of a minimum tax on profits of the... Continue"},{"titre":"Italian business calls for tax simplification measures","url":"https://kluwertaxblog.com/2024/11/29/italian-business-calls-for-tax-simplification-measures/","pubDate":"Fri, 29 Nov 2024 16:05:33 +0100","description":"On 22 November 2024 more than 300 tax experts gathered in Rome for the first Italian International tax conference organized by Italian Association of Joint Stock Companies (Assonime). Under the patronage of the OECD, the European Commission and the Italian Ministry of Economy and Finance (MEF), the event brought together business representatives and institutions to... Continue","id":1742310,"source":"Kluwer International Tax Blog"},{"pubDate":"Thu, 07 Nov 2024 16:05:01 +0100","titre":"Your Homework Will Be Graded: The ECJ’s Apple Decision and Its Implications for International Tax","url":"https://kluwertaxblog.com/2024/11/07/your-homework-will-be-graded-the-ecjs-apple-decision-and-its-implications-for-international-tax/","id":1685685,"description":"This blog post was first published on the Kluwer Competition Law Blog.   On September 10, 2024, the European Court of Justice (ECJ or Court) sided with the European Commission (Commission) and ruled that two Irish subsidiaries of Apple Inc. received unlawful state aid from Ireland in the form of a tax advantage (Case C-465/20... Continue","source":"Kluwer International Tax Blog"},{"description":"We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Han Kogels, Will the Road to Carbon Neutrality Become Even More Bumpy Than Ever? The first-ever global stocktake of what has been achieved and what still must be achieved since the 2015 Paris Agreement... Continue","id":1632428,"source":"Kluwer International Tax Blog","titre":"The Contents of EC Tax Review, Volume 33, Issue 05, 2024","url":"https://kluwertaxblog.com/2024/10/15/the-contents-of-ec-tax-review-volume-33-issue-05-2024/","pubDate":"Tue, 15 Oct 2024 16:15:37 +0200"},{"id":1306638,"description":"Although the meaning of beneficial ownership in tax treaties first burst onto the scene in Indofood International Finance Ltd v JP Morgan Chase Bank N.A. London Branch [2006] EWCA Civ 158 and, for the first time in Canada in Prévost Car Inc. v R 2008 TCC 231, (affirmed 2009 FCA 57), its meaning and application... Continue","source":"Kluwer International Tax Blog","pubDate":"Mon, 06 May 2024 22:26:15 +0200","url":"https://kluwertaxblog.com/2024/02/12/stock-lending-beneficial-ownership-and-tax-avoidance-again/","titre":"Stock lending -beneficial ownership and tax avoidance- again!"}]