This article deals with the problems of taxation of controlled foreign companies (hereinafter: CFC) in the light of the contemporary process of economic integration, international tax law and the European Union law. In general, the Controlled Foreign Companies rules (hereinafter: CFC rules) can...

In this article, the author explores and advocates the use of an artificial intelligence tax treaty assistant with regard to resolving issues and problems in respect of the principal purpose test as proposed in relation to the OECD/G20 Base Erosion and Profit Shifting initiative. As the PPT is...

The purpose of this article is to demonstrate that the introduction of legal definition of aggressive tax planning (ATP) together with anti-ATP rules by the European Commission under the Securing the Activity Framework of Enablers (SAFE) initiative is an example of legislative inflation of the...