Publications
Insights
Notes first published on LinkedIn — one argument each, the instrument named, the money followed.
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8 September 2026
Latvia is redrawing the line between capital and distribution
Two tax bills tabled in one month move the line the same way — and decide, receipt by receipt, which tax, at which level, and whether the 3% applies.
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26 August 2026
Belgium's flat 7% surcharge on non-residents fails Article 45 TFEU
A national stand-in for a municipal tax that some municipalities never levy cannot track what it replaces — C-119/24, and a pattern that travels.
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24 August 2026
The 5% is a category, not a discount
The simplified mark-up for low value-adding services comes with a category test — and in Latvia a wrong category costs 25 cents in the euro, in cash, with no profit precondition.
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21 August 2026
A buy-back is not a sale
Two shareholders leave the same company on the same day for the same money; one is taxed on a gain, the other on a distribution. The tax follows whoever wrote the cheque.