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Alexander Linn The Tax Court of Cologne has referred three separate cases regarding the application of Germany's anti-treaty shopping rules to the Court of Justice of the European Union (CJEU). The court questions whether the rules are compatible with the freedom of establishment principle in the Treaty on the Functioning of the European Union (TFEU) and/or the EU Parent-Subsidiary Directive.

Maria Anastasiou Afrodita Taci Transfer pricing legislation was introduced in Croatia by way of the Corporate Income Tax Act (CIT) on January 1 2005. However, the Croatian tax authorities have only recently recognised its importance, with advance pricing agreements (APAs) recently being implemented in Croatian tax legislation.

Spain has introduced groundbreaking requirements for companies to file transactional data in near real-time. Joe Stanley-Smith examines the case study of global battery company Duracell to explore how companies are dealing with the extra workload from the Suministro Inmediato de Información (SII) legislation, one month on from its implementation on July 1 2017.

Another day, another Donald Trump policy in tatters

Tiago Cassiano Neves Dinis Tracana The Portuguese tax authorities (PTA) issued a ruling on July 21 2017 that has the novelty of providing for the first time some guidance on the interpretation of the permanent establishment (PE) concept for corporate income tax (CIT) proposes in the framework of some operating models. The following is a brief summary of the facts and conclusions underpinning this ruling.

Alexander Tokarev Ivan Nasonov In 2015, the 'beneficial owner of income' concept was introduced into the Russian Tax Code. Since 2017, foreign companies claiming treaty benefits in Russia are obliged to provide the Russian companies paying them income with documentary proof of their status as beneficial owners of this income.

Lewis Lu Curtis Ng Many readers will be familiar with the famous conclusion of Justice Rowlatt in Cape Brandy Syndicate v IRC, [1921] 12 TC 358 that: "In a taxing act, one merely has to look at what is clearly said. There is no room for any intendment. There is no equity about a tax." And Lord Tomlin's statement in the Duke of Westminster case (Duke of Westminster v IRC, 19 TC 490) that: "This so-called doctrine of "the substance" seems to me to be nothing more than an attempt to make a man pay notwithstanding that he has so ordered his affairs that the amount of tax sought from him is not legally claimable." This approach to interpreting tax law has recently been under threat from the 'tax fairness' agenda.

Khoonming Ho Lewis Lu In the course of May to July 2017, a series of new Chinese regulations relaxed restrictions on foreign inbound investment while, at the same time, enhancing the tax and regulatory enforcement capacity of Chinese government authorities.

The tax status and characterisation of passive holding companies has gained renewed interest with Article 7 of the OECD’s Multilateral Instrument (MLI) containing some reference to these entities. Mauro Manca of Giovannelli e Associati looks at how these structures can still work if there are sound organisational reasons in the MNE structure.

The tax regimes governing the gig economy, combined with the rules on self-employed individuals, have led to the success of companies such as Uber and Deliveroo. However, the Taylor Review on modern working practices has suggested radical changes that could change it all and stop other sectors adopting similar practices. Anjana Haines talks to the report’s author, Matthew Taylor, to discuss his recommendations and what they could mean for the future of the gig economy.