Canada vs Thompson: Exploring the Limits of Attorney-Client Privilege in Tax Enforcement
In Canada (National Revenue) v. Thompson, the Supreme Court of Canada evaluated the boundary between solicitor-client privilege and the statutory obli…
Month: October 2024
Orde van Vlaamse Balies vs Belgium: Legal Privilege and Cross-Border Tax Reporting Obligations
In Case C-694/20, the European Court of Justice (ECJ) examined the legality of certain reporting obligations imposed on lawyers under Council Directiv…
EU State Aid in Transfer Pricing and its International Relevance
State Aid, an important concept within the European Union's (EU) legal framework, serves to prevent competitive imbalances by prohibiting member state…
ENGIE vs EU: State Aid Decision in the EU’s Effort to Combat Selective Tax Advantages
This case involves the European Commission's ruling that Luxembourg’s tax rulings for ENGIE constituted unlawful state aid, creating tax advantages …
Tax Risk Management: Importance of the Tax Steering Committee
Tax Steering Committees (TSCs) are essential for multinational corporations seeking to ensure tax compliance, manage tax risks, and align tax strategi…
Introduction to International Taxation: Key Concepts & Guidelines
International taxation governs the tax framework applicable to cross-border activities of individuals and corporations. It addresses the tax treatment…
The Challenge of Blocked Income in Transfer Pricing
The issue of blocked income in transfer pricing arises when multinational enterprises (MNEs) face legal, tax, or regulatory barriers that prevent the …
Why is Relinquishing Tax Residency More Scrutinised Than Acquiring It?
In this Q&A, we dive into Brian Arnold’s perspective on why a facts-and-circumstances test is applied more rigorously when a taxpayer gives up resid…
How are source rules that consider income from where business is carried on too vague for guidance?
In this video, we explore Brian Arnold's critical perspective on the vagueness of source rules in international taxation, focusing on how the term "wh…
Is double non-taxation a BEPS concern, and can a multilateral instrument prevent it?
In this Q&A session, we explore a scenario involving international double taxation, where domestic tax laws and treaty provisions result in double non…