This article aims to examine the role of the subjective element in how certain transactions should be taxed according to the international tax system in cases of tax abuse and aggressive tax planning (ATP). This article also analyses the nature and the different scope of the taxpayer's...

Multinational enterprises make use of aggressive tax planning strategies because they are able to operate in the legal vacuum that exists between nation states. The tax burden is not mitigated by falsifying the facts of tax-relevant events (as in the case of tax evasion) or through simulation of...

This article addresses a massive topic: tax competition and trends in aggressive tax planning matters. In particular, the article aims at demonstrating how the concepts of "tax competition" and "tax coordination" must be rephrased after the introduction of the notion of "aggressive tax planning"...