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The Data Economy: On Evaluation and Taxation

While data-centred business models are claiming an ever-growing share of worldwide revenue, regulatory efforts to identify proper tax rules for the relevant activities are intensifying. It is questionable whether or not the proposals currently on the table capture the distinctive…
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Italy Clarifies Key Transfer Pricing Tenants

During Telefisco 2019, Italy’s annual tax conference, Italy’s tax authority clarified several transfer pricing (TP) tenants. Notably, the most important include: Clarification regarding when penalty protection may be applied to TP documentation; and The inapplicability of penalties for filing discrepant…
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International Tax Dispute Resolution: New EU Rules

lnternational tax disputes arise, in principle, where there is a bilateral or multilateral treaty for the avoidance of double taxation (hereinafter “Double Tax Convention” or “DTC”) or an equivalent instrument and the contracting jurisdictions exercise their taxing power in a…
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Geotaxation and the Digital: Janus in the Mirror

Geopolitics has been defined as ‘great power competition over access to strategic locations and natural resources’. In essence, it focuses on the impact of geography on international political relations and vice versa. The principal actor in international political relations is…
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