Using unique tax audit data of 499 German firms, we analyze whether family firms, public firms, financially constrained firms, and those firms with managers with low tax morale substitute two tax strategies, book-tax conforming and nonconforming tax avoidance strategies, and examine the effect...

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...

The objective of this study is to show that an indirect interest in a controlled foreign corporation (CFC) through hybrid participation instruments may not be subject to CFC taxation. This is the case where the taxpayer holds a hybrid participation instrument in a foreign intermediary company...

Estonia’s tax mix has been traditionally reliant on consumption taxes—especially VAT—whereas income taxes are a relatively small share of revenue. Recent and expected changes will further shift the tax burden in this direction. Consumption taxes are less distortive than income taxes, but...

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...

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...

This research investigates the impact of tax justice perception and tax understanding on the compliance of Small and Medium-sized Enterprises (SMEs) with government regulation Number 55, 2022, in Surabaya. The study, conducted at KPP Pratama Surabaya Wonocolo employs a quantitative approach,...

In einer Zeit rasant fortschreitender digitaler Transformation spielt Künstliche Intelligenz (KI) eine zunehmend zentrale Rolle in verschiedensten Bereichen unserer Gesellschaft. Diese Schrift widmet sich speziell der Bedeutung und den Auswirkungen der KI im Steuerrecht. Wie kaum ein anderer...

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...

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...

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...

Sri Lanka’s taxation has two key burning issues. One is the consistent reduction of tax to GDP ratio over the last three decades, which reached its lowest of 8.4 in 2020 (CBSL,2020). This means the government revenue is extremely low, resulting in persistent budget deficits. The second issue...

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 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...

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...

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...