In this paper it is controversially suggested that international tax law is broader than the traditional view of most academics. In addition to domestic laws that cover cross-border transactions and double taxation agreements (or their multilateral counterparts) there is a special consensus...

A faltering procedure for cross-border enforcement of sanctions under the Council Directive 2010/24/EU of 16 March 2010 concerning mutual assistance for the recovery of claims relating to taxes, duties and other measures (TRD), has contributed to a degree in uncertainty and a wavering protection...

This article addresses some aspects of the impact of the fairness requirement on international administrative cooperation for the cross-border recovery of taxes and the influence of the case law of the European Court of Justice (ECJ) in this area. This case law relates to the interpretation of...

This article explores the possible involvement of tax specialist ombudsmen in the mutual agreement procedure (MAP). With the current level of development of the MAP still facing criticism for a lack of efficiency and transparency, and the arbitration only being adopted by a handful of states,...

The GloBE proposal intends to comprehensively address the remaining BEPS challenges and tax competition issues ensuring that the profits of multinational enterprises are subject to a minimum effective tax rate. Nonetheless, the public consultation held in November 2019 gave evidence of different...

This article demonstrates that despite its importance as a normative criterion for the international tax system, it is difficult to apply the standard of fairness for several reasons, including the lack of a general accepted definition thereof. Moreover, additional difficulties arise due to the...