Query : Tax rulings
- Derenne, Jacques2
- Aiche, Yaniss1
- Alvarez, Victoria Soledad1
- Anđelković Mileva1
- Andrzej Niezgoda1
- Beatriz Iñarritu1
- Bürgisser, J.1
- Carrel, Marion1
- Cottin-Marx, Simon1
- Danny Lenin Espinosa Taipe1
- Danon, R.1
- David Ordóñez Solís1
- Dodik Siswantoro1
- Elżbieta Agnieszka Ambrożej1
- Emilio Margin Manautou1
- Gabriella Perotto1
- García Núñez, Domingo1
- Gauthier, Aurélie1
- Gerson Moscoso Becerra1
- Guido Bellenghi1
- Political Science16
- Economies and Finances2
Tax Rulings Under State Aid Scrutiny
The time accounts of the Bishop of Troyes between 1420 and 1426: a testimony of stability in time of war
La Champagne Sud is rather an oral tradition, but the Etienne de Givry (1395-1426) pioneer in the drafting of the accounts of the Bishop. Oral means have little place in the stability of these monetary documents, as the general receiver relies on different media to cover debts, compulsory letters or...
Transparency and crisis in the legitimacy of the French tax administration: the publication of the rulings
The French tax system enables taxpayers to obtain an opinion from the administration on a proposed arrangement or transaction by means of an application for a preliminary ruling. Until now, these rulings were secret, with no text obliging the administration to publish them. Official reports address...
The Correlated Factors of Mandatory Social Reporting by Islamic Banks in Indonesia
<p><strong>Objective –</strong> Islamic Banking is closely related to the real sector. Then, its operation should reflect the real sector which is expected to contribute to the sustainable economic growth. Nevertheless, Islamic banks are still benchmarking the price of their products (profit sharing...
Chronology of the case-law of the Court of Justice of the European Union
Summary: I. Introduction. From Skouris to Lenaerts. — II. First part. Developments in the case-law of European Union law. 2.1. The limits of fundamental rights and EU law: privacy and equality. 2.2. The construction of the European area of freedom, security and justice. 2.3. Offences in tax matters...
Communitarian Chronicle: Spanish up-to-date institutional and economic framework within the European Union (June 2018)
Summary: I. Introduction. — II. The State of Integration. 1. Proposal to deepen the Economic and Monetary Union. 2. Brexit: Agreement on the terms of the Brexit transition period. 3. Luis de Guindos, Vice-President of the ECB. — III. General issues of current economic issues. 1. ECB: Announcement of...
The General Court in Amazon and Engie: A New Effect-based Approach Aimed at the Endorsement of the 'Vestager Doctrine'?
(Series Information) European Papers - A Journal on Law and Integration, 2021 6(2), 1097-1116 | European Forum Insight of 29 October 2021 | (Table of Contents) I. Introduction. - II. The facts of the cases. - III. The annulment of the commission's decision in the Amazon case. - IV. The court dismiss...
The protection of tax claims in insolvency proceedings: relevance or interference
The doctoral thesis entitled ‘Protection of triburary claims: relevance or interference’ is intended to study the conduct of the tax claim when insolvency proceedings are declared against the person liable for payment. As a multipley study, the work is based on two legal disciplines, insolvency and...
Financial innovation and taxation
This article attempts to illustrate some aspects of the relationship between financial innovation and taxation without ambition. Three angles of view are taken to illuminate the subject. The first explores the existing relationship between tax rulings linked to state budgets and their implications f...
Harmful tax competition within the European Union: from tax rulings to financial transaction taxes
peer reviewed In this presentation, I will outline how the EU constitutional framework reacts against harmful tax competition, in addition to showcasing the limits and negative consequences of that approach.
Participatory strategic foresight as a managerial innovation. The case of French Guiana
The praise for foresight in general and strategic business foresight in particular is no longer to be done. In a context of crisis, businesses have an urgent need to anticipate change, in the interests of survival. This momentum is the same among the small and medium-sized enterprises in the tax rul...
The importance of the principle of ability to pay in the Ecuadorian tax system
The Constitution of the Republic of Ecuador, in Article 300, has not included the principle of ability to pay as one of the maximum values that shape the national tax system. However, through several judgments, the Ecuadorian Constitutional Court has issued very valuable rulings on the importance of...
Tax Ruling Regulations in Poland – Evolution of the Institution and Evaluation of the Regulations
This contribution deals with tax ruling in Poland, its evolution, evaluation of legal solutions concerning it, as well as the practice of issuing those rulings by competent tax authorities. The main objective of the contribution is to confirm the hypothesis that legal regulations concerning tax ruli...
THE LEGAL NATURE OF THE MANAUS FREE ZONE (ZFM) TAX ADVANTAGES: TRIBUTARY OR ISENTION IMPACT
The ZFM model can be seen as an example of successful public politics because it has contributed over the past 50 years to the development of the region. This article deals with the legal nature of the tax incentives offered by the ZFM. The discussion on this topic is striking and very important for...
Selectivity in Fiscal Aids: Recent Developments
The notion of fiscal aid is becoming crucial in determining the relationship between supra-national integration and national tax sovereignty; the selectivity criterion is often key in the assessment of compatibility of fiscal measures with Article 107(1) TFEU. Therefore, the notion of sele...
Has Ecuador been able to address tax challenges caused by the globalisation of the economy and aggressive tax planning schemes?
in recent years, the global economy has been forced to evolve due to various factors, such as the origins of the digital economy, the strengthening of international trade relations and the perennial pursuit of capital investors for higher returns. All of this has given impetus to international marke...
Economic and Political Considerations of the Court’s Case Law Post Crisis: An Example from Tax Law and the Internal Market
This paper investigates whether the ‘Euro crisis’ has altered the Court of Justice’s legal reasoning in the area of the four freedoms and direct taxation. In view of the tremendous budgetary implications of the Court’s judgments in the area of direct taxation, this paper departs from the hypothesis...
Judicial Review of Taxation Authorities’ Decisions on Reliefs in Payment of Tax Liabilities Based on Administrative Discretion
The article is of a scientific-research nature. The author discusses the problem of limits of judicial review of discretionary decisions made by taxation authorities, which aim at applying relief in payments of tax liabilities under Polish regulations and case-law of administrative courts. It may be...
Tax developments for 2014. First rulings of the Supreme Court of Justice of the Nation
This document refers to tax issues that entered into force as of the first of January this year. And the first resolutions of the SCJN.
Chronic EU Tax Law — The Court of Justice issues four dividend tax rulings
(CJEU, 7th Ch., 30 January. 2020, case C-156/17 (1st esp.), Köln-Aktienfonds Deka v Staatssecretaris van Financiën; CJEU, 6 rd Ch., 21 January. 2020, case C-613/18 (2nd esp.), Estado do Canadá v Autoridade Tributária e Aduaneira; CJEU, 5th Ch., 2 April. 2020, Case C-458/18 (3nd esp.), ‘GVC Services...
Pre-trial detention in the light of the conventionality check. The combination of proportionality and the proper reasoning of tax rulings as a rule in Peruvian criminal proceedings
The purpose of this article is to argue that the proportionality test and the proper reasoning of tax rulings should be considered as a rule, and imprisonment as the exception, defeat, which will be based on a unified inter-American legal standard based on a conventionality review, which will raise...
Measuring Success of the Czech Financial Administration before the Supreme Administrative Court: Partial Results of a Quantitative Research of Court Proceedings
The paper discusses the issues of the actions and measures of tax authorities challenged by taxpayers before the administrative justice and thus serves as a contribution to the discussion on efficiency of tax authorities and public administration in general. The authors first address the currently d...
Preliminary tax opinion: Plaidoyer for its redesigning in Serbian tax law
Advance tax ruling represents a missing link in Serbian tax law. It is aimed at advancement of taxpayers' legal certainty and deals with the tax treatment of their future transactions. By issuing a ruling at the taxpayer's request, the tax administration obliges itself to issue a tax decision with s...
Governmental Jurisprudence in the Eyes of Imam Khomeini (ra)
Shiite jurisprudence is constantly changing. With the victory of Islamic revolution and rule of community jurisprudents, many questions relating to area of jurisprudence in the Islamic community were shifted to system of jurisprudence where jurisprudent approaches opted to answer them thanks to thei...
Will the European Union put an end to the “golden age” of tax ruling?
The article deals with the problematic of evolution of regulation of tax rulings. The author indicates the main trends in this process. The most important is that more and more often the holder of the tax ruling is not protected by it. The lack of protection is justified by the desire to combat tax...