July 2017  
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Issue No. 7 - 2017 of the European Taxation is now available online.

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Number 7 - 2017 contains the following:

Taxless Corporate Income: Balanced Against White Income, Grey Rules and Black Holes

Piergiorgio Valente

The potential of globalization and digitization is clearly manifested in international taxation, currently undergoing a complete overhaul. A key factor driving the transformation is “stateless income”. Although this term is extensively used, its meaning is ambiguous. It might be said to comprise flexible income earned by multinationals or simple taxpayers through virtual or cyber transactions. Primary liability for its creation seems to lie with state legislators, who should hence act to remedy the situation.


State Aid and Tax Rulings – An Assessment of the Selectivity Criterion of Article 107(1) of the TFEU in Relation to Recent Commission Transfer Pricing Decisions

Han Verhagen

The author, in this article, explores whether or not the European Commission’s approach to the selectivity criterion in its recent State aid decisions in the area of transfer pricing is in line with ECJ case law.


Tax Proceedings in Norway: An Overview Including Recent Decisions of the Supreme Court

Clement Endresen

In this article, the author provides a short introduction to tax proceedings in Norway, including a description of the recent restructuring of the tax administration. The main part of the article provides a survey of tax cases decided by the Supreme Court that involve procedural issues, most of which also have to be dealt with in other jurisdictions.

Oana Popa
Oana Popa
Oana Popa

Tax Treaty Interpretation in Germany: Utilizing the OECD’s New Approach to the Qualification of Income

Adrian Cloer and Franziska Sixdorf

The authors, in this note, present the decision of the Lower Fiscal Court of Berlin-Brandenburg in Case 15 K 1093/10  regarding the qualification of income for the purposes of applying tax treaties, including a discussion of its implications on tax treaty interpretation in Germany.


The Web Tax and Taxation of the Sharing Economy: Challenges for Italy

Marco Allena

In this note, the author discusses the complexities of Italy’s attempts to tax digital transactions, including the introduction of a web tax, as well as tax measures aimed at the sharing economy.


A Lose-Lose Situation: EU Freedoms Versus Italian Taxation on Winnings Prior to Recent Italian Amendments

Davide Attilio Rossetti and Stefano Guarino

The Italian Regional Tax Court of Naples, on 14 October 2016, determined that the tax regime applicable to winnings arising from Italian and European casinos restricts the freedom to provide services within the European Union, which is consistent with previous ECJ case law. Given the ECJ’s longstanding stance on this issue, it is surprising that the Italian legislator waited until 2016 to amend the law. This note describes the Regional Tax Court’s decision, as it represents a valuable tool in understanding the relationship between Italian legislation and EU law.

Tax Reform in Latvia

Zigurds G. Kronbergs

In this note, the author describes recent initiatives aimed at a reform of the Latvian tax system, in particular with regard to the micro-enterprise tax, and discusses problems that might lie ahead.

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