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Tax Disputes

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In Cross-Border VAT Fraud

Germany: Negotiations with EPPO in a VAT evasion case – key lessons learned

by and 3 Mins Read

Background The European Public Prosecutor’s Office (EPPO) recently opened a criminal investigation against a non‑EU multinational company for alleged VAT evasion amounting to EUR 80 million. The company operates an online platform through which retailers sell directly to consumers across Europe. Assuming that VAT obligations rested with individual traders, the company did not file VAT returns in Germany. The German tax investigation office, however, classified the business model as proprietary trading and therefore considered the…

In Attorney-Client Privilege

United States: In re Grand Jury

by and 4 Mins Read

In brief After initially granting certiorari and hearing oral arguments in In re Grand Jury ─ a matter concerning the application of the attorney-client privilege to dual-purpose communications ─ the United States Supreme Court “dismissed as improvidently granted” the case. Tax practitioners had hoped that a ruling by the Supreme Court would resolve a circuit split regarding the extent to which such communications fall within the ambit of the privilege. Background As a general rule, a lawyer’s…

In International

OECD MAP statistics continue to demonstrate the effectiveness of the dispute resolution mechanism

by , and 12 Mins Read

In brief On 22 November 2022, the Organization for Economic Co-operation and Development (OECD) released the Mutual Agreement Procedure (MAP) statistics for 2021 (“MAP Statistics”). The 2021 MAP Statistics were produced pursuant to Base Erosion and Profit Shifting (BEPS) Action 14, which seeks to improve the resolution of tax-related disputes between jurisdictions. In Depth The MAP Statistics cover 127 jurisdictions in 2021 (up from 118 jurisdictions in 2020) and nearly all MAP cases worldwide, and…