This paper reveals how tax complexity, in the form of loopholes and assets overlapping different sections of tax returns, contributes to tax avoidance and evasion. Using administrative data from the Netherlands, it shows how an auditing announcement in 2005 triggered large increases in declared...

Weisen allgemeine Antimissbrauchsvorschriften verschiedener Steuersysteme trotz unterschiedlicher Ausgestaltung mehr Ähnlichkeiten auf als es zunächst scheint? Um diese Frage zu beantworten, befasst sich die Autorin in ihrer Arbeit mit dem Recht Hongkongs, Singapurs und der Volksrepublik China...

Taxation of cross-border services has been identified as a high priority issue in the United Nations (UN) negotiations to establish a new global framework for tax. This paper analyses the defects of international tax rules as applied to services, and their exploitation by multinational...

In this paper, we attempt to estimate the tax revenues to be gained by the Member States of ATAF, WATAF, AU and the South Centre under the Amount A and an alternative stylized DST taxation regime. Our research demonstrates that the comparative revenue effects of the Amount A and DST taxation...

The paper discusses the European Commission’s tax policy agenda in business income taxation and the ongoing legislative initiatives in this regard as per early 2022. The focus is on the Commission Communication titled ‘Business Taxation for the 21st Century’ of 18 May 2021 and the...

A government's primary duty is to provide its people with public services, for which it needs funding to cover its costs. Taxation, among other things, serves as a significant source of funding for public spending. The government has been able to uncover new avenues for revenue collection...

This is the fifteenth in a series of sixteen papers about the U.S extraterritorial tax system.This article:- Cautions against any new U.S. tax system that would perpetuate the constitutional and human rights violations of the current system; - Explains how other countries are able to further the...

GPT-4 performs vastly better than ChatGPT or GPT-3.5 on legal tasks like the bar exam and statutory reasoning. To test GPT-4’s abilities, we ran it on our final exams this semester and graded its output alongside students’ exams. We found that it produced smoothly written answers that failed...

Taxation is one of the few things that we can take as a given in life. People will always look for ways to minimize the tax burdens that governments seek to impose on them. Indeed, there is a very well-developed industry devoted to that end. How should governments proceed? We develop an economic...

This article presents an overview of the history of tax dispute resolution in Canada. It traces the history of Canada’s system of tax dispute resolution through eight distinct phases from 1918 through to the present-day operation of the Tax Court of Canada. With this history outlined,...

This Essay is based on my presentation to Temple University Beasley School of Law for the 2022 Frank and Rose Fogel Lecture Series. This is not intended to be a transcript of my remarks given on October 11, 2022, but instead, an opportunity to provide additional information regarding the Tax...

This paper seeks to identify two key differences between the U.S. tax law and Nigerian tax law with the aim of comparing the different approaches identified and commenting on what each country might learn from the other country’s approach. For this purpose, it was necessary to, first, identify...

Tax planning is part of modern financial management worldwide, and the countries of Central Europe are no exception. Tax havens provide opportunities for managers to increase companies profits through tax reduction. Naturally, there are differences in ownership structures; therefore, the...

We examine an international panel of domestic firms to quantify the degree to which conforming tax avoidance changes with statutory tax rates. We derive an alternative estimation method that identifies conforming tax avoidance from the variation of tax rates over time and across countries. We...

The Earned Income Tax Credit, a federal anti-poverty program administered through the tax system, provides a total of about $65 billion a year in “refundable credits” (a payment in excess of tax liability) to more than 25 million working low-income taxpayers, who receive an average of about...

The main aim of this study is to present the basic principles of taxing revenue derived from activities carried out by farmers in Poland, resulting from the regulations of tax law in Poland, and propose solutions concerning that law as it should stand. These are revenues derived from...

This paper focuses on the technical assistance report on international taxation challenges and options in Guatemala. The topic of treaties has garnered special attention in Guatemala as of late, requiring a strategy to be devised. Treaties foster a better business climate and can encourage...

The purpose of this article is to study the tax sustainability of agricultural companies in Ukraine. This article developed the following working hypotheses, which were derived from the main purpose of the study. The methodology for the assessment of tax sustainability has been improved due to...

Countries wishing to reform their tax system must consider that their proposals are in line with both international trade law and international tax law, which, if on the one side, are two different branches of international law, on the other side, they share overlapping elements in relation to...

This is the tenth in a series of sixteen papers about the U.S extraterritorial tax system.The U.S. extraterritorial tax system violates multiple provisions of international human rights instruments that have been signed, or signed and ratified, by the United States. The rights in question...

As democracies around the world have faltered, legal scholars in fields as diverse as election law, labor law, and administrative law have turned to tax law to repair and support democratic governments. Taxation offers a toolset well equipped to address concerns raised by democratic theorists...

Das Werk behandelt das „Bezahlen mit Daten“ aus umsatzsteuerrechtlicher Sicht. Ausgehend von der (steuer)rechtlichen Einordnung künstlicher Intelligenz werden die Auswirkungen des Einsatzes künstlicher Intelligenz in Geschäftsmodellen auf das bestehende Besteuerungssystem dargestellt und...

This paper explores the effects of fiscal capacity on the rule of law. Following the Besley and Persson (2009) model exploring complementarities between fiscal capacity and legal capacity, we test the relationship using fiscal capacity and rule of law data from the Varieties of Democracy...

This paper explores the effects of fiscal capacity on the rule of law. Following the Besley and Persson (2009) model exploring complementarities between fiscal capacity and legal capacity, we test the relationship using fiscal capacity and rule of law data from the Varieties of Democracy...

For the buyer, a cross-border acquisition presents mostly tax opportunities, such as maximizing the tax deduction for acquisition indebtedness or amortizing acquired intangibles. The tax pitfalls, such as taxation of gain on the sale, are mainly the seller's problems, and the seller can be...

The world today has become a global village and commercial transactions can be carried out from one end of the globe to the other without the need for physical presence, thanks to the unprecedented technological growth and innovations of recent decades. With the even recent developments in...

Tax avoidance attracts a great deal of attention from both academics and policymakers. To combat the phenomenon, Congress has enacted numerous statutory provisions that either deny beneficial treatment when one of the taxpayer’s principal purposes was tax avoidance or attempt to dissuade...