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European UnionMaarten de Wilde[1] and Ciska Wisman[2] Summary In this contribution, the authors operationalize a concrete numerical example to explain why all top-up tax variants under the EU Pillar Two Directive collide with the notions of the internal market and the fundamental freedoms. The various top-up tax mechanisms under the Directive impose differences in tax treatment... Continue readingRead Article
Why all top-up tax variants in the EU Pillar Two Directive collide with the EU’s fundamental freedoms (and how to solve this) - Kluwer International Tax Blog

Netherlands · NetherlandsHighlights & Insights on European Taxation Please find below a selection of articles published this month (May 2025) in Highlights & Insights on European Taxation, plus one freely accessible article. Highlights & Insights on European Taxation (H&I) is a publication by Wolters Kluwer Nederland BV. The journal offers extensive information on all recent developments in European Taxation in the area of direct taxation and state aid, VAT, customs and…Read Article
The Contents of Highlights & Insights on European Taxation - Kluwer International Tax Blog

Singapore · SingaporeIntroduction On 22 May we delivered an opening address on the current practical challenges of dispute prevention and resolution at the International Tax Dispute Day organized in Singapore by the Tax Policy Center of the University of Lausanne and the Singapore Tax Academy. While acknowledging the progress made since the adoption of BEPS Action 14 in relation to the mutual agreement procedure (“MAP”) of tax treaties, we observed (at least based o…Read Article
The effectiveness of the Mutual Agreement Procedure and the global tax controversy landscape: some critical observations on current pressure areas and suggestions to improve the framework - Kluwer International Tax Blog
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