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...

Assume a hypothetical but very plausible scenario in which you had invested substantial fortune and efforts in a cross-border transaction. You entered this transaction after a thorough field study and you even consulted some tax experts in order to estimate your potential tax burden. The tax...

This paper focuses on commenting on two separate aspects: (i) whether the current international tax environment that is leading us to some sort of “Imperial Taxation”, where taxpayers' rights are being eclipsed by State's revenue needs; and (ii) whether the BEPS Project might actually foster...