Accountants, and to a lesser extent also (tax) lawyers, have been arguing for decades now on the content and practical consequences of the True and Fair View Principle. This papers tries to demonstrate that: i) True and Fair View is nothing different from what lawyers already know under...

Many developing countries have been trying to expand in the last decades their taxing powers on cross-border services rendered by non-residents beyond the rigid framework of the current international tax regime. However, this expansion has been carried on unilaterally and sometimes in an...

The objective of this contribution is to provide the OECD with a view to designing the final 2020 Report, the EU Institutions projecting an eventual legislative action and whatever States considering or (re)considering unilateral measures in the field of taxation of the digitalized economy with...

This note briefly analyses the Halifax decision of the ECJ on Tax avoidance in European VAT and deals with the unresolved problem of abusive behaviors in relation to pure collecting rules (as limited exemptions in European VAT)

This contribution tries to anticipate the possible consequences of the eventual introduction of an EU GAAR in the so called Anti-BEPS Directive for GAARs that already exist in the Domestic Law of EU Member States

This position paper provides possible solutions to the challenges presented to the international tax regime by the digital economy. It considers the option of installing a broad withholding mechanism based upon the base erosion principle both as a primary response to these challenges or in...

This book chapter analyses the policy rationale and interpretation issues arising from 1) the general interest deduction limitation rule envisaged in the Spanish Corporate Income Tax Act (article 16 CITA), which is aligned with the BEPS action 4 proposal to limit base erosion involving interest...

Spanish Abstract: La pandemia del Covid-19 ha restringido la libertad circulación imponiendo presencias forzadas o, al menos, no deseadas. Estas presencias pueden desembocar en consecuencias tributarias imprevistas sobre todo en relación con la fiscalidad internacional. La reacción de la...

For years the advent of the digital economy has left countries stumped in their attempt to tax income earned by foreign firms without physical presence within their jurisdiction. International organizations and their member countries have failed in their attempts to tweak the rules of the...