This article is focused on the Court's decision in Hornbach-Baumarkt (Case C-382/16) (Hornbach) which is an important clarification of the conditional compatibility of arm's length-based domestic transfer pricing legislation with the freedom of establishment. Hornbach follows and confirms the...

This study was developed based on the IBFD EU Task Force's submission within the framework of the European Commission 2021 public consultation on the use of shell entities and arrangements for tax purposes. The analysis of the broad ramifications of this central issue within corporate tax law...

The taxation of multinational enterprises is currently subject to intensive international and national debates. In these debates the Netherlands has sometimes been labelled as a ‘tax haven'. This term has a strong negative connotation. In any case, a country's reputation is at stake if it is...

This paper outlines the core issues of the introduction of a new PE nexus based on digital presence. It puts forward its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global economy. Our proposal of a new PE nexus based on digital...