tax law. Others call the case‘‘Marks & Spencer revisited on the branch level.’’ In fact,both statements are correct. The … applicabledouble taxation convention provides for an exemptionof the branch profits in that country. Contrary to Marks& Spencer (C-446 …

International tax law is going through a period ofremarkable change. Trends come and go frequently;however, three …

Time and again, a decision of the German FederalTax Court (Bundesfinanzhof, or BFH)makes an international tax planner … anti-treaty-shopping rule in the landmarkHilversum II decision. (For prior coverage, see‘‘German Tax Court Revamps Treaty … ShoppingLaw,’’ Tax Notes Int’l, Oct. 10, 2005, p. 122, and‘‘German Tax Authorities Disregard Hilversum IIRuling,’’ Tax Notes Int …

-Calcio. It is furthermore shown that the specialty ofSalva-Calcio, imposing a tax cut for national Clubs, points towards a more …

standard model we concentrate on tax reforms that are both Pareto effcient and Pareto improving. Also, we assume the capital … tax rate can never rise above its initial level and lump-sum transfers between agents are impossible. We study the whole … all these elements in the analysis changes considerably the nature of tax reforms. In particular, capital taxes have to be …