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New taxing right to be an overlay to the arm’s length principle The OECD Secretariat proposal for a unified approach published today for consultation until 12 November focuses on Pillar One (nexus and profit allocation). A separate public consultation document dealing with Pillar Two (remaining BEPS issues) is expecte... Now and tomorrow: European Commission assesses future of blockchain Today, the European Commission's Joint Research Centre published a flagship report exploring the challenges and impacts of blockchain and distributed ledger technologies.   The report offers an in-depth and practical understanding of blockchain, moving be... Directors of large French companies may be presumed French tax resident The French Draft Finance Bill for 2020, as published on 27 September, includes a provision introducing a presumption that individuals holding a corporate office in a large French company (i.e. a company which, together with its subsidiaries, has an annual... International Tax Competitiveness The Tax Foundation has published its annual International Tax Competitiveness Index. Countries are ranked by competitiveness in respect of specific aspects of their tax regime. The index also provides an "overall" ranking which Estonia continues to lead: ... Automatic transfer of certain French tax cases to the Public Prosecutor On 27 September, one of the key measures introduced by the recent Anti-Fraud Law (which was adopted by the French Parliament on 23 October 2018) has been confirmed by the French Constitutional Council. This important decision is in response to a request f... Who pays UK corporation tax? Earlier this week, HMRC published their annual corporation tax statistics, and they provide some interesting insights into who is paying the tax. Total CT liabilities increased from £50bn to £55bn from 2016/17 to 2017/18, despite the one per cent fall in ... What can we learn from Starbucks and Fiat? The European Court ruled yesterday that the EU Commission had not been able to demonstrate that the advance pricing agreement between Starbucks and the Dutch tax authority amounted to illegal State aid.  The Starbucks Dutch company concerned was responsib... Rule of tax law or rule of tax judges? «There is no liberty if the judiciary power be not separated from the legislative and executive» (C.L. de Montesquieu, The Spirit of Laws, Book XI, 6 Of the Constitution of England, 1748). For centuries, the principles of the separation of powers and judi... 'Technology, Access to Justice and the Rule of Law': a new report from the Law Society Despite the rapid technological changes which have taken place in the past few years, disrupting almost all facets of our lives, there has been a marked decline in access to justice since the 2008 recession. In a report published on 16 September 2019, the... Where should the holding company be? In any cross-border merger transaction, an early question will often be where the holding company for the merged group should be located.  This is not just a tax question - the location of the business, stock market requirements and practical issues for t...