Within the European Union, there exists a fundamental tension between the fiscal sovereignty of its Member States, in particular in the field of direct taxation, and the requirements of the Internal Market, which aim at the abolition of any regulatory or fiscal obstacles to cross border movement...

In recent years, there is a growing tendency in international taxation to move the right to tax the corporate income of multinational enterprises to the jurisdiction where their customer base is located. One widely discussed proposal applies a sales-only formula to group-wide profits of...

The European Union is in the process to establish “public country-by-country reporting” as a new and wide reaching obligation for multinationals to disclose tax-relevant numbers to a global audience, going beyond the OECD consensus which combined cross-border exchange of reports with...

European Law plays a major role in the implementation of the BEPS Action Plan by Member States of the European Union. How does this influence the interpretation of primary and secondary EU law? On the one hand, recent secondary legislation like the Anti-Tax-Avoidance Directives explicitly aims...

The scope of coherence, as a ground justifying measures interfering with the fundamental freedoms, is limited by the concept of macro-coherence. This article analyses the origin and rationale of macro-coherence and how the concept relates to the balanced allocation of taxing rights. The authors...