This study explores the alignment of digital services taxes (DSTs) with the non-discrimination provisions outlined in the General Agreement on Trade in Services (GATS) with particular attention being paid to the concept of ‘likeness’. It focuses on the Italian DST as a representative case and examines whether this measure differentiates between ‘like’ digital services and suppliers in accordance with Articles II (Most-Favoured Nation (MFN)) and XVII (National Treatment (NT)). The analysis employs a doctrinal approach and integrates a comprehensive examination of World Trade Organization (WTO) law with relevant case law and tax scholarship. This reveals that revenue thresholds and carve-outs introduce structural asymmetries in the competitive relationship between services and suppliers that may be regarded as ‘like’ under WTO criteria. The Italian DST is ostensibly neutral but disproportionately impacts large multinational platforms thereby posing a significant risk of de facto discrimination under current jurisprudence. This study expands on this insight and argues that a model DST law crafted in accordance with the GATS principles is essential to ensure that future digital taxation initiatives fulfil their fiscal objectives without violating multilateral trade regulations.

Bitcoin’s sixteenth anniversary in 2025 provides an important juncture to reflect on how tax law has responded to the emergence of crypto assets. Initially hailed as ‘the monetary experiment of our time’, Bitcoin and its successors have challenged fundamental tax concepts and exposed divergences in domestic and international tax systems. This article first revisits the debate on whether crypto assets should be characterized as ‘money’, demonstrating that classification matters only to the extent that tax consequences diverge across regimes. It then examines four unresolved issues that continue to occupy scholars and policymakers: the characterization of mining rewards as entrepreneurial income or windfall gains; the treatment of staking rewards as active or passive income; the tax consequences of blockchain hard forks; and the classification of collateral use of crypto assets in decentralized finance. Each issue reveals tensions between traditional tax analogies and the novel features of blockchain-based activities, highlighting trade-offs between theoretical purity and administrability. While global convergence is unlikely due to foundational differences in tax systems, the analysis underscores the importance of clarity, consistency, and functional approaches to ensure that taxation keeps pace with technological innovation.

In this article centred on the OECD’s Crypto-Asset Reporting Framework (CARF), a leading US tax practitioner based in Zurich shares his expectations on the fall-out from the incoming crypto asset reporting regimes. Grounding his views in precedents from recent tax reporting for conventional asset classes, he forecasts resistance from the industry and investors, leading to novel enforcement challenges faced by tax authorities when confronted by an agile and motivated target. In closing, he sets out a series of enhanced enforcement proposals that tax authorities might adopt to further CARF compliance.

Tax systems are often assumed to be neutral, yet they can reinforce gender inequalities in practice. This article examines how this inequality is embedded in both the design and administration of tax systems in developing countries using Nepal and Zambia as case studies. The analysis is grounded in a framework drawn from sound principles of economics and public financial administration. The article distinguishes between explicit bias – legal or administrative provisions that directly differentiate between men and women – and implicit bias that arises from seemingly neutral tax rules that reflect and reproduce gendered economic roles. The article uses case studies to illustrate how these biases manifest in income, consumption, and trade taxes as well as in tax and customs administration. It argues that well-designed tax policy and public financial management reforms can raise revenue more efficiently and equitably, support inclusive growth, and advance gender equality. The article concludes with recommendations to align tax policy and administration with gender-equitable development goals.

This article examines the evolving scope of professional privileges (PPs) in EU tax law and focuses on recent judgments by the Court of Justice of the European Union (CJEU), most notably C-623/22 Belgian Association of Tax Lawyers and C-432/23 F SCS, both rendered in 2024. These can be considered as a continuation of the C-694/20 C-694/20 Orde van Vlaamse case that was decided in 2022. The CJEU’s decisions address the tension between the state’s need for information disclosure – specifically in the context of preventing tax evasion and avoiding aggressive tax planning – and taxpayers’ fundamental rights, particularly the right to legal advice and legal professional privilege (LPP). This right is essential for the proper functioning of society as it allows individuals to seek professional advice without fear of disclosure. The article explores the balance that the CJEU had to find between these competing interests in light of EU legal instruments governing the exchange of information (EoI) and mandatory disclosure rules (MDR). Through a critical assessment of recent case law, the article highlights key lessons and provides insights into the scope of various PPs in the area of EU tax law shaped by the CJEU’s gavel.

The emergence of the digital economy has made user data a valuable asset at commercial levels. This commercial appeal translates into economic benefits for those digital companies that manage to collect, select, and sell it. Data mining and its business (with the actual international tax regulation and awaiting international agreements for implementing measures based on, for example, a new tax nexus) is difficult to subject to tax in the place where the users of the data collected reside. For this reason, it is necessary to search for other solutions and study the possibility of considering data mining as a permanent establishment (PE) similar to a mine, a well, or any other place of extraction of natural resources. Likewise, it will be necessary to analyse the concept of a user and their value creation within the digital economy from a tax perspective.