The role of the Taxation Section is to coordinate the activities of the following committees.
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This panel, at the 11th Annual IBA Finance & Capital Markets Tax Virtual Conference, discussed a selection of European Union measures and developments, starting with the United Kingdom experience after Brexit, then discussing the recent European Commission proposal for a Directive regarding shell entities of 22 December 2021 (COM (2021) 565 final, expected to be implemented by June 2023 with effect from 1 January 2024, and some case studies on withholding tax challenges.
The Double Taxation Treaty between Colombia and the United Kingdom entered into force on 1 January 2020, and unlike other treaties in force, it excluded payments for technical services, technical assistance and consulting services from Article 12 (Royalties). Therefore, absent a permanent establishment, payments for those services would no longer be subject to a ten per cent withholding tax but would be treated as business profits. On these grounds, the analysis of the most favoured nation clauses agreed between Colombia and other countries became critical. The analysis was performed by Colombia's tax authority in a ruling issued in early 2020. Although official rulings are not binding to taxpayers, they are mandatory to tax officials. The analysis is explained in this article.
India has recently provided a framework for the taxation of crypto assets. The move has been appreciated by the industry; however, in the authors’ view, the regressive tax policy adopted may do more harm than good.
Due to the urgent need to mitigate the climate crisis, the carbon credit mechanism has been seen as a new market business opportunity that the private sector in particular has been investing in globally. The current lack of legal provision in Brazil on the definition of the legal nature of carbon credit operations has allowed a broad scenario of debates and interpretations of the definition and relevant legal regulatory and tax impacts connected to it.