This paper proposes a new framework to assess the impact of Court of Justice of the European Union (CJEU) jurisprudence on Internal Market-related areas, by considering whether the jurisprudence of the Court on corporate taxation fulfils the constitutional mandate, as set-out in the European...

Within Europe differentiated rates structures date back to the introduction of VAT itself. Evidence as regards the negative consequences of applying multiple rates has been apparent for some decades. In this context, since the late 1980s, there have been several attempts to amend European rates...

The current international tax system based upon the principles of source and residence is no longer suited to a globalised world economy, and the fundamentals of the international tax system need to be re-examined. An R+F based cash-flow tax based on the principle of destination has been...

On February 2006 the Court of Justice delivered its eagerly awaited ruling in Halifax, a case concerning the interpretation of EU secondary legislation on VAT. The judgment represented the culmination of a long process, with the Court referring for the first time to the 'principle of prohibiting...

The theoretical and practical advantages of the VAT have led to its adoption in some form or another by most countries and by many hundreds of subnational administrations worldwide. However, nowhere is VAT found without exemptions. Exemptions are arguably the most controversial feature of VAT...

Within Europe differentiated rates structures date back to the introduction of VAT itself. Although evidence as regards potential negative consequences of applying multiple rates was unavailable at that time, difficulties have been apparent for some decades. In light of this reality, since the...

This paper provides a legal and economic analysis of the European Commission’s recent proposals for reforming the application of VAT to financial services, with particular focus on their “third pillar”, under which firms would be allowed to opt-into taxation on exempt insurance and...

The aim of this paper is to establish whether VAT place of supply rules are more effective allocation rules than international tax rules currently governing income taxation. This is done through the analysis of the “place where the activity is effectively carried out” (PWAECO) and the...

From the outset, turnover taxes have played a fundamental role in the European integration process. Harmonisation of these taxes was perceived an integral part of achieving a common market, and for this reason it was given priority. Over forty years since the introduction of a common VAT system,...

The taxation of financial services is one of the most vexing aspects of a Value Added Tax (VAT). Conceptually, VAT should apply to any fee for service but where financial services are concerned there is a difficulty in identifying the taxable amount, i.e. the value added by financial...