This paper examines the legal consequences and assesses the economic impact of the differing tax treatment of investment funds in Portugal, Germany, and Luxembourg before and after the Allianzgi-Fonds case decision. Before the Allianzgi-Fonds case decision the Portuguese investment taxation...

The European Commission recently implemented the minimum tax directive (Pillar Two) to ensure that corporate profits are at least taxed at 15%. At the same time, it proposed a legislative initiative aimed at reducing the tax-induced distortions between debt and equity financing (debt-equity bias...

The recent enactment of Directive 2021/2101 by the EU introduces a public Country-by-Country Reporting (CbCR) regime, with the aim of promoting a level playing field for businesses operating within the EU Single Market. The directive seeks to bolster tax transparency requirements for...

This paper evaluates the Multilateral Convention to implement Pillar I Amount A, released by the OECD in October 2023, and the alternative proposal of Art. 12B for tax treaties suggested by the UN, with a particular emphasis on the perspective of developing countries. We conduct a comparative...

We examine the costs associated with public disclosure, as opposed to confidential reporting, of tax country‐by‐country reporting (CbCR) information. Our study addresses a critical knowledge gap, considering the growing adoption of public tax transparency measures. We aim to illuminate this...

This paper examines the legal consequences and assesses the economic impact of the differing tax treatment of investment funds in Portugal, Germany, and Luxembourg before and after the Allianzgi-Fonds case decision. Before the Allianzgi-Fonds case decision the Portuguese investment taxation...

The European Commission recently implemented the minimum tax directive (Pillar Two) to ensure that corporate profits are at least taxed at 15%. At the same time, it proposed a legislative initiative aimed at reducing the tax-induced distortions between debt and equity financing (debt-equity bias...

The recent enactment of Directive 2021/2101 by the EU introduces a public Country-by-Country Reporting (CbCR) regime, with the aim of promoting a level playing field for businesses operating within the EU Single Market. The directive seeks to bolster tax transparency requirements for...

This paper evaluates the Multilateral Convention to implement Pillar I Amount A, released by the OECD in October 2023, and the alternative proposal of Art. 12B for tax treaties suggested by the UN, with a particular emphasis on the perspective of developing countries. We conduct a comparative...