There is a widespread perception, often aired by politicians, the media and NGOs, that multi-national companies are not paying their ‘fair share’ of tax. The G20 have made the issue of tax base erosion and profit shifting (BEPS) a priority and tasked the OECD with taking action to bring...

To operate efficiently and effectively revenue authorities require discretion, but processes must be in place to keep discretion in check. This delicate balancing act takes place against the background of a more general constitutional framework. This working paper starts by outlining the unique...

The schedular system of income tax in the UK frequently comes under attack, not least in relation to the distinctions it draws between the tax treatment of the employed and the self-employed. However, on examination, it appears that non-schedular systems of taxation share both these distinctions...

In the USA there have been calls for greater conformity between the rules producing tax accounts and those used for financial reporting purposes. A number of benefits are claimed for this so-called ‘book-tax conformity’, including reduced compliance costs and better opportunities for...

This chapter considers the taxation of small, owner-managed businesses. It focuses on the difficulties created by treating employees, unincorporated and incorporated businesses differently for tax and social security purposes. The authors reject blanket tax incentives for small firms and...