This chapter reviews the development and present Canadian law on the residence of corporations for tax purposes. It highlights a few of the elements of Canada's corporate law regime by way of context; outlines why residence matters to corporations for Canadian tax purposes, traces the history of...

This article examines the notion of the elimination of economic double taxation, an obstacle to the functioning of the internal market, in the context of the Directive and the EU fundamental freedoms. In the context of the fundamental freedoms, its elimination is a necessary step toward...

"This book on international tax multilateralism is composed of 11 chapters, which comprehensively discuss the meaning of multilateralism in international taxation from various complementary perspectives, as well as the impact of the base erosion and profit shifting project (BEPS Project) in the...

Albania journey towards EU membership is governed by the Stabilization and Association Agreement (SAA), signed on June 12th, 2006. This article rises above Albania's obligations for the alignment of its tax legislation with EU standards and acquis, clearly defined in Title VI of the SAA. Unlike...

Upon more than 400 judgements on direct taxation, the case law of the European Court of Justice has considerably shaped Member States' tax systems. Based on Member States' tax law adjustments in the context of four landmark rulings on corporate income taxation, we analyse whether case law is a...

The European Court of Justice's decision in Kerckhaert-Morress, allowing double taxation of the same income, leads to stagnation in the European internal market. Over the past thirteen years, reservation of competences to member states has created a tension between the European Community's goal...