The paper discusses the European Commission’s tax policy agenda in business income taxation and the ongoing legislative … utilizing political momentum in the international tax policy debate as a driver to further a decades-old ambition of a European … Union wide harmonised unitary company taxation system in combination with a tax base distribution key based on a formulaic …

), administrative guidance that limited Internal Revenue Code (the Code) section 382, an important tax rule designed to discourage tax …-motivated acquisitions. Although styled as a mere interpretation of existing law, the Notice has been widely viewed as an improper exercise … interventions during the financial crisis that raised questions about eroding the rule of law and the long-term destabilizing …

provide for any ex ante guarantee on the compliance of BEPS with EU law. To ensure that the important goals of global tax …The article aims to demonstrate how EU law and the OECD are establishing a unifying conceptual framework in which the … two different seminal phenomena, "tax abuse" and "aggressive tax planning", can be acknowledged in the new (global …

-term comprehensive tax policy reform. A unitary taxation approach with formulary apportionment in the European Union is better suited to … international tax policy environment. It would restore faith in fairness of the European tax system, while also allowing for further …

tax law. The not legally binding Code defines harmful tax measures. The Code is generally regarded to be an effective …The European institutions strive for more open and informal governance. The use of soft law is part of the new … Member States in a non-binding way. The Code of Conduct for Business Taxation is a well-known soft law instrument in European …

tax laws if they violate EU law. Therefore, a new calculation method for taxation with a progression proviso is developed … to bring the EU Member States' tax legislation in line with EU law. The study expands the literature on taxation and …This study analyzes whether the tax progression proviso's calculation method for foreign income exemptions under a tax …

tax authorities or claim a VAT refund to which they are not entitled. We find that pre-reform fraud amounts to around 4 …

In this research paper, we attempt to estimate the tax revenues to be gained (or lost) by the South Centre and African … private sector researchers but did not involve review of any information that taxpayers provide to tax authorities. Our …

much more purposivist over time. In contrast, the Tax Court has not grown more normative and has followed the same trend … toward textualism as most other courts. But although the Tax Court has become more broadly textualist, it prioritizes … suggests that each authority adopts its own flavor of textualism or purposivism.These findings complicate the literature on tax …

order – can be considered compliant with European tax law and case law, based on the definitions of criminal and tax …

This contribution makes the attempt to elaborate a diagnosis on the maturity of the EU corporate tax, as the result of …, which is currently identified with the protection of domestic tax bases as a result of the BEPS measures. Therefore … tax system under 3 prongs: lack of coordination, the progressive elimination of the distinction between Primary and …

expansion has been accelerated by the exposure of secrecy jurisdictions that facilitate tax evasion and avoidance, while the …-taker because its territorial tax system benefits little from information exchange …

farmers in Poland, resulting from the regulations of tax law in Poland, and propose solutions concerning that law as it should … research on two levels. The first consists of the provisions of the agricultural tax law in Poland, dating back to 1984. The … Agricultural Tax as well as in the provisions of the Polish Act on Goods and Services Tax, regardless of whether they are carried …

This study examines the evolving landscape of anti-tax avoidance measures in the European Union (EU), focusing on the … interplay between the Anti-Tax Avoidance Directive (ATAD), the EU Blacklist Code of Conduct on Business Taxation, various … unilateral regulations, and the global minimum tax. Drawing on a comprehensive survey of local tax experts, we investigate how …

corporate shells with high tax loss carryforwards for the tax asset to be utilized in profitable companies. However, other …

, and to show a certain disciplinary unity of Mining Tax Law, as a specialty of Tax Law with a strong link to Mining Law and … rather than properly formulating a general theory of mining tax law … Economic Law, among others characteristics. To do so, it tries to unravel specific problems, concepts and categories that are …

define and direct behavior of fiscal law subjects, to represent itself as a standard basis for tax disputes resolutions. The … which establishment by the federal law provides implementation and observance of the fundamental rights of the …". Highlighting a special role of the fiscal law principles, the Slovaklawyer V.Babchak considers them "a sort" of blood-grooves "of …

international tax law making by international organizations and the role of the OECD in respect of OECD and non-OECD countries … address the relationship between legitimacy and international tax law making. The second part will address the role of the … legitimacy will address the shared goals i.e. to tackle tax fraud, tax evasion and aggressive tax planning and the solutions …

Tax departments and their external advisors are increasingly required to deal with the tax law of foreign jurisdictions …. This practical new guide is the first to provide a comparative approach to help you understand tax law interpretation in … comprehensive interpretation of the law in the areas of VAT and GST or other general sales tax, along with corporate income taxes …

variation between the currently used Separate Accounting and tabled Formulary Apportionment distribution of corporate tax base … most significant relative declines of over 15% in the corporate tax base would be faced by Luxembourg, Malta, Cyprus, the …. If cross-border consolidation of losses is incorporated in the envisaged corporate tax framework, the EU-wide aggregate …

need to enlist consumers in tax enforcement to boost tax compliance. …

This paper documents the rise of corporate tax-base narrowing measures in the EU using a novel dataset covering both … tax rate and tax base reforms implemented between 2014 and 2022. Our findings indicate a shift away from the ’cut rate … EU tax competition exerts downward pressure on high-tax countries, while the likelihood of tax cuts also varies with the …

This paper examines the Corporate Income Tax (CIT) compliance gap, the difference between revenue due under full … mismatches between national accounts and tax data, and reliance on unverifiable assumptions. To address these issues, the Joint …

The purpose of this article is to study the tax sustainability of agricultural companies in Ukraine. This article … assessment of tax sustainability has been improved due to the development of indicators of tax sustainability at all levels of … the tax hierarchy. Our study confirms the hypothesis that the tax sustainability of Ukraine is worse than that of OECD …

tax structure in the Philippines. The Philippines is currently drafting a law imposing VAT on these services, which is …This paper aims to describe the state of multilateral and unilateral efforts to tax digital services; summarize the … (DSTs), especially on revenue streams of large nonresident digital platforms. To do this, the country must update its tax …

" for the 2015 annual meeting of the European Association of Tax Law Professors in Milan. Professors participating in the …This is a thematic report on the topic of "Administrative Surcharges: Instruments of Cooperative Tax Compliance Regimes … meeting were surveyed regarding their countries' use of tax penalties and other surcharges. The Report first examines how the …

This paper examines the legal consequences and assesses the economic impact of the differing tax treatment of …-Fonds case decision the Portuguese investment taxation discriminated against foreign investments by levying a withholding tax …-exemption extended to non-resident UCITS will lead to tax neutrality treatment of investment funds in the EU. Overall, we confirm that …

and if so, to what extent primary Union law might require the Union legislator, too, to base its tax legislation on …Arguably, any tax fairness rule requires an even-handed taxation of taxable persons according to a universal standard … of tax equality, or tax equity, rooted in ethical values. In modern civilized societies such values are often enshrined …

How does EU law affect Member State corporate tax systems and the cross-border activities of companies? This book … traces the historical development of EU corporate tax law and provides an in-depth analysis of a number of issues affecting … the case law of the Court of Justice, as well as the Commission's burgeoning external tax policy initiatives. The book not …

, the place of decisions of the European Court of Human Rights in the system of sources of tax law, the problems arising …The purpose of this article is to explore the subject of applying to the European Court of Human Rights in tax cases … from the application of ECtHR decisions by Ukrainian courts in tax cases. The research was carried out using formal …

Multiple jurisdictions have been and continue to converge their taxation frameworks to eradicate cross-border tax …-resident investors and establish rules to prevent and detect cross-border tax evasion. The US began this convergence with its Qualified … simplification of cross-border withholding tax across 27 Member States (“FASTER”). Once agreed upon, the Directive is expected to go …