How should “Europe” respond to society’s calls for a sound and properly functioning corporate tax system for the internal market? With the aim of contributing to the deliberations on this subject, the proposal of the author is to remodel the CCTB/CCCTB draft directives into a unitary...

Today we live in a globalizing economy: national open markets are steadily developing towards a global market. Within the European Union, the internal market without internal frontiers has been established. However, the fiscal sovereignty of nation states remains limited to economic activities...

How countries tax the profits of multinational enterprises has become hopelessly outdated. The recent OECD/G20 Base Erosion and Profit Shifting Project has left the existing international corporate taxation framework essentially intact. Perhaps it is time to consider a truly fundamental reform...

This paper addresses the recent developments surrounding the political agreement reached on 8 October 2021 within the Inclusive Framework on Base Erosion and Profit Shifting on a reform of the international business taxation framework under the heading ‘Addressing the tax challenges arising...

The international corporate income and capital gains tax (CGT) systems of basically all modern nation states share a common objective. All seek to effectively ‘capture' multinational enterprises (‘MNEs') that are economically present within the respective taxing state's geographical borders...