Digital taxation is one of the most contentious areas of international tax policy. On August 6, 2020, the United Nations (UN) Committee of Experts on International Cooperation in Tax Matters released a draft of the proposed new Article 12B for the UN Model Double Taxation Convention between Developed and Developing Countries (UN Model). The […]
Monthly Archives: August 2020
Week in Review - August 14, 2020
Vancouver Neighbourhood Declares 'Tax Resistance' Until Local Homeless Population Provided Shelter and Supports: Residents of the Strathcona neighbourhood in East Vancouver, B.C., are pledging to withhold property tax payments until a local homeless encampment is dealt with by government officials. Local media in Vancouver are reporting that over 300 people are estimated to be […]
Commentary: UK Applies 0% VAT on Digital Advertising by Charities, But Questions Remain
HM Revenue & Customs (“HMRC”), the UK’s equivalent of the CRA, recently updated its policy on charity digital advertising. The refined policy applies zero value-added tax (“VAT”) tax on five types of digital advertising by charities, all of which target an aggregate of IP addresses, rather than singling out individuals. As we know, VAT is paid at the […]
The UN Tax Committee Weighs in on “Digital Services”: A New Article 12B for the UN Model Tax Convention?
The initial proposal of a drafting group of the United Nations Committee of Experts on International Cooperation in Tax Matters has recently been released. This proposal arises from proceedings of the Committee in late June of this year. It is important to understand the context of UN work of this nature. The members of […]
Week in Review - August 07, 2020
Canada's Budgetary Deficit "Manageable" Without Tax Increases if COVID-19 Response Measures Ended Soon, Says Parliamentary Budget Officer: Canada's Parliamentary Budget Officer (PBO) Yves Giroux made comments to media this week that indicate that his office believes that Canada's currently unprecedented budgetary deficit is "manageable" so long as COVID-19 economic response programs are ended soon. […]
Supreme Court of Canada Grants Leave to Appeal for Alta Energy Luxembourg Treaty Shopping Case
On August 6, 2020, the Supreme Court of Canada (“SCC”) granted leave to hear the case between the Crown and Alta Energy Luxembourg (“Alta Luxembourg”). The Federal Court of Appeal (“FCA”) had released its decision in The Queen v. Alta Energy Luxembourg S.A.R.L., 2020 FCA 43 (“Alta Energy FCA”) earlier this year on February […]
Time to Start W(h)ining: The Federal Government Announces (Partial) Agreement with Australia to Repeal Excise Duty Exemption on Canadian Wines
On July 27, the Minister of Small Business, Export Promotion and International Trade, Mary Ng, issued a sobering blow to Canadian wineries and their patrons. After a World Trade Organization (WTO) challenge against Canada from Australia claiming “discriminatory measures,” Ms. Mary Ng announced that the two countries had come to a (partial) agreement that […]
Commentary: South Korean Government Proposing 20% 'Crypto Tax'
South Korea is proposing to introduce a cryptocurrency tax ('crypto tax') that will impose a 20% tax rate on cryptocurrency income that is 2.5 million won, about $2,000 US, or higher. The proposed crypto tax bears some interesting contrasts with the Canadian tax authority's approach to the increasingly popular cryptocurrency: The proposed crypto […]