This article analyses a proposal for a new regulation of the European Parliament and of the European Council, which objective is to establish new guidelines to improve the operation of the taxation systems in the European Union as well as to support the fight against tax fraud, tax evasion, and...

FATCA is a US domestic tax policy that requires Foreign Financial Institutions around the world to provide the IRS information regarding their US clients. Recognizing this extraterritorial characteristic and the troubles associated with it, the US Treasury Department developed the...

The benefits of a tax treaty are generally granted to persons who are residents of one of the Contracting States. The determination of such tax residence status is, however, not always an easy task and is particularly problematic in relation to entities whose tax characterisation differs from...

This article provides a brief analysis of the Court of Justice of the EU decision of 16 March 2021, C 562/19 P European Commission v Republic of Poland, addressing issues of state aid and progressive turnover taxation

It has recently been argued in the international tax literature that the OECD Base Erosion and Profit Shifting project (BEPS) reflects and effectuates full taxation, namely an international norm that would suggest that all of a company's income should be taxed in places where it has real...

This Essay argues that EU taxpayers may challenge digital services taxes as violations of EU law. Specifically, because they exempt all but the very largest companies, which are disproportionately foreign, DSTs result in nationality discrimination as applied. As part of our analysis of the...

This contribution summarises the main aspects of the EU General Court’s decision and explores some of its lessons for the future of state aid regulation in the European tax law context. Most notably, it critically evaluates the reasoning of the EU General Court to uphold the use of the OECD...

The Foreign Account Tax Compliance Act (FATCA) is a US domestic tax policy that requires Foreign Financial Institutions around the world to provide the IRS information regarding their US clients. Recognizing this extraterritorial characteristic and the troubles associated with it, the US...

Corporate Taxation, Group Debt Funding and Base Erosion' is the first in-depth analysis of the features and implications of the directive, and it provides insightful and practical discussions by experts from around Europe on the crucial interactions of the Anti-Tax Avoidance Directive (ATAD)...