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Lib(e)ra(tion)? Probably not from regulation
On Tuesday the Libra Association, an association established by Facebook, published a white paper setting out a proposal for a new simple global currency with somewhat unambitious aims such as to "reinvent money" and "transform the global economy". The ne...
What BERT knows
In a lecture theatre that once featured in the movie Inception, Sebastian Riedel discusses how that particular film didn’t make any sense: “It’s not internally consistent. There are points where a person falls in dream level L+1 but fails to wake up in d...
Bitcoin collusion: see you in court?
The previously hypothetical application of antitrust laws to the world of cryptocurrency is now a reality in United American, Corp. v. Bitman, Inc., a case before the courts in the US State of Florida. The case is most recently awaiting a decision on the...
Co-opting digital companies into tax law enforcement
Today, The Times reported that some 38,000 online sellers registered for VAT in the UK in 2017-18, compared to 29,000 in the previous year and just 5,000 three years earlier. Why this increase? Since March 2018, UK legislation requires operators of online...
Co-opting digital companies into tax law enforcement
Today, The Times reported that some 38,000 online sellers registered for VAT in the UK in 2017-18, compared to 29,000 in the previous year and just 5,000 three years earlier. Why this increase? Since March 2018, UK legislation requires operators of online...
Taxing the digital economy: impact assessments will help identify winners and losers
The G20 has endorsed the OECD's work programme consisting of the two-pillar approach which was the subject of Tanja Velling's recent post. The G20’s communiqué shows that there is political support at the highest level for this project and it is full ste...
How low is low taxation? – The reform of the German CFC rules
Germany's controlled foreign corporation rules (CFC rules, Hinzurechnungsbesteuerung) date back to 1974 and have never really been modernized. Low taxed income, for instance, is understood as income subject to a corporate income tax rate of 25%. In the me...
The tax residence of companies. A matter of fact, or a fact that does not matter?
In her recent post, Tanja Velling highlights some of the uncertainties in the UK around the tax residence of a company. This is not just a UK issue, as it is far from being clear in many other countries. For companies not belonging to a group, agreeing on...
New Residents First!
Italy is facing a dramatic outflow of “human capital”. According to Eurostat, only Romania and Poland pips Italy to the post in terms of emigration to other EU countries. But back to Italy: 30% of those who leave have a university degree (the rest are uns...
All clear on tax residence?
The First-tier Tax Tribunal's unhelpful decision in the Development Securities case has been reversed by an Upper Tribunal decision which was published today and (at least for now) provides comfort that a lot more is required than a subsidiary's acquiesce...