The current international corporate tax regime for taxing the business proceeds of firms operates arbitrarily. The aggregates of the nation states' international corporate tax systems seem to distort a global efficient allocation of resources. The model is ill-suited to current market realities....

In this paper, the author sets out a proposal for an alternative, more neutral system for taxing multinationals. His suggestion is that multinationals should be treated as a single taxable entity and granted an allowance for equity capital provided by shareholders. The proposal geographically...

In this article, the author examines, through numerical examples, the effects would EU Member States subject taxpayers – both residents and non-residents – deriving income from domestic sources, to unlimited income taxation whilst granting double tax relief for foreign income under a...

How should “Europe” respond to society’s calls for a sound and properly functioning corporate tax system for the internal market? With the aim of contributing to the deliberations on this subject, the proposal of the author is to remodel the CCTB/CCCTB draft directives into a unitary...

Winds of change have been blowing through the world of international company taxation, with company tax planning and country tax competition increasingly attracting questions from the general public, the media, politics and academia. The most systemic corporate tax reform proposal in the EU so...

This paper elaborates on the provision on tax abuse in the EU's Anti Tax Avoidance Directive (‘ATAD'): the general anti-abuse rule (‘GAAR'). The GAAR allows EU Member States to disregard for company tax purposes any non-genuine arrangements that have been put in place to defeat the object or...

The author examines the lowering of the threshold at which commissionaire, auxiliary, and building site and construction activities qualify as a permanent establishment under the Multilateral anti-BEPS Convention (MLI). With a view to countries planning to implement the provisions in this...

The author addresses the phenomenon of taxable profit-shifting operations undertaken by multinationals in response to countries competing for corporate tax bases within the European Union. The central question is whether this might be a relic of the past when the European Commission's proposals...

The OECD is holding public consultations on 13 and 14 March 2019 on the challenges facing countries' corporate tax systems as a result of the ever-increasing digitalisation of the economy. As part of these consultations, a document listing the problems at stake and suggestions for possible...

The starting points in international taxation, as used by countries around the world to establish and divide tax jurisdiction and as the basis for the charge to tax income, embed an idiosyncrasy of analytic indistinctness. The residence and source principles are geographically geared in the same...