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...

The paper is the result of the Doctoral Course 'The abuse of the concept of abuse in tax law' that was taught in Bergamo 2008. The paper stresses the problems for having different approaches to tax avoidance and, therefore, tax abuse, and tries to reconcile the different approaches from a...

The OECD Multilateral Instrument (MLI) is unique to the extent that it is not self-standing, but only modifies the application of tax treaties entered into by its signatories. As acknowledged in the ‘Toolkit' annexed to the final report on BEPS Action Plan 15, this raises significant questions...