Author: Amedeo Rizzo The international tax landscape is undergoing a significant transformation with the proposal of a global minimum tax for multinational enterprises (MNEs). The Organisation for Economic Co-operation and Development (OECD) has conceived this initiative to combat international corporate tax avoidance, proposing a 15% minimum tax on large multinational groups. This proposal has gained…
Author: Amedeo Rizzo Journal: Stanford – Vienna Transatlantic Technology Law Forum, Transatlantic Antitrust and IPR Developments, Issue No. 1/2023 Abstract: The EU Foreign Subsidies Regulation (“FSR”) has been published on the 14th of December 2022 and entered into force on 12 January 2023. The Regulation creates a new regime with the objective of protecting the internal market…
Author: Amedeo Rizzo Publication: Cambridge International Law Journal Blog Abstract: The adoption of the global minimum tax reflects quite an unprecedented level of cooperation in the history of international tax and constitutes a strong signal in the international community, bearing a two-fold message. On the one hand, it shows countries’ willingness and shared effort to prevent tax…
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Author: Amedeo Rizzo Journal: TTLF Working Papers No. 101, Stanford Law School Abstract: This paper analyzes the use of intellectual property rights and the most common forms of tax measures to incentivize innovation and conducts a comparative analysis between the policies adopted by the US and the European Union.The first part of the paper will focus on…
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Authors: Erika Scuderi, Amedeo Rizzo, Artemis Locaidou Book: Dominic De Cogan, Alexis Brassey, Peter Harris, “Tax Law in Times of Crisis and Recovery” (Bloomsbury) Abstract: The COVID-19 pandemic has had tremendous effects on both human health and the global economy. Lockdown measures, however, led to the unpredicted effect of improving the quality of the environment and lowering…
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Authors: Amedeo Rizzo, Martina Acciaro Journal: Stanford – Vienna Transatlantic Technology Law Forum, Transatlantic Antitrust and IPR Developments, Issue No. 2/2022 Abstract: The role of the digitalization of the economy has increased over the years and has been recently accelerated by the COVID-19 pandemic. This phenomenon originates critical issues for tax authorities, as digital activities are often outside the…
Authors: Pitambar Das, Amedeo Rizzo Journal: International Tax Studies, 2021 Abstract: The OECD Unified Approach under Pillar One deviates from the existing international business tax rules in many aspects. First, it extends the right to tax business profits on the basis of mere sales in addition to the existing “physical presence” nexus rule. Second, the…
Authors: Pitambar Das, Amedeo Rizzo Journal: Bulletin for International Taxation, 2022 Abstract: The authors, in this article, examine the implications of the global minimum tax as proposed by the OECD under Pillar Two regarding the taxation of corporations, and whether the proposal will realize its stated policy aims. The objective of the GloBE proposal is…
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Authors: Amedeo Rizzo, Erika Scuderi Journal: Fiscalità & Commercio Internazionale, 2020 Abstract: The COVID-19 pandemic seems to have eclipsed the environmental crisis. Of course, priorities on the European (and international) political agenda have radically changed due to the dramatic health emergency and its devastating economic effects. The sharp reduction in global economic activity during the…
Authors: Yue Daisy Dai, Amedeo Rizzo Journal: Fiscalità & Commercio Internazionale, 2020 Abstract: In 2020, Italy implemented its Digital Services Tax (DST), in line with the one proposed by the European Commission and then implemented by other countries such as the U.K., France and India. The objective of the tax is to tax the “digital…