This paper discusses the current trial of McKesson Canada Corporation v. The Queen in the Tax Court of Canada and the related-party debt factoring arrangement and transfer pricing issues between McKesson Canada Corporation and McKesson International Holdings III S.A. R.L, a company resident in...

Every nation has an interest in sharing the gains they help create by participating in globalization. If governments fail to claim an adequate share of these gains, they will be forced to look ever more intensely to personal taxes on their own already-burdened citizens. Yet because of the...

This is an Opinion Statement prepared by the CFE ECJ Task Force on the Commission v Spain case (also cited as the 'Form 720' case), in which the First Chamber of the Court of Justice of the EU (ECJ) delivered its decision on 27 January 2022. The Court, in its decision, ruled in favour of the...

Luxembourg receives ample investment from multinational corporations, in part due to some attractive features in its international tax rules. Around 95 percent of these foreign investments pass through Luxembourg via companies performing holding and/or intra-group financing activities. While...

States have complex and often conflicted attitudes toward migration and citizenship. These attitudes are not always directly expressed by lawmakers, but they may be reflected quite explicitly in tax regimes: for the world's most prosperous individuals and their families, multiple states extend a...

Advance tax rulings are a common feature of mature tax systems. The tax systems of the United States, the United Kingdom, the Netherlands, Germany, Australia, and South Africa all have established ruling practices. Taxpayers can obtain an advance tax ruling in nearly all OECD member countries....

Over the past few years, policymakers have argued that everything from Apple's Irish tax deal to patent boxes to the LuxLeaks tax rulings represent “harmful tax competition.” Despite the ubiquity of this term, however, there is no internationally accepted definition of so-called harmful tax...

This Study contains the final version of the document elaborated by the IBFD Task Force on the Digital Economy as a submission to the European Commission in the framework of its 2021 Public Consultation on the possible introduction of an EU digital levy. Based on a reconstruction of the...

This article is a commentary on the decision of the Court of Justice of the European Union on the Vodafone case, C-74/78 on progressive turnover taxes.In our view, the Court’s decision provides clarifications for ascertaining the compatibility of domestic turnover taxes with the fundamental...

This Handbook entry presents a conceptual, normative overview of the subject of taxation. It emphasizes the relationships among the main functions of taxation—notably, raising revenue, redistributing income, and correcting externalities—and the mapping between these functions and various...