This paper analyses the possibility of double non-taxation of hybrid instruments in cross border transactions where the country of the investor has implemented the indirect credit method for mitigation or elimination of double taxation. From an isolated perspective a double non-taxation cannot...

The compartmentalisation of company finance into equity and debt does not truly capture the enormous diversity of financial instruments available. A wide variety of hybrid instruments incorporate elements of both equity and debt. From a fiscal point of view the classification of such hybrid...

This article proposes a conceptual foundation for the field of international tax law. The article refers to this foundation as the institutional competence of nations in global economic development. A nation's institutional competence is its discretion to make decisions in pursuit of our...

Social security is a fundamental part of workers' lives in three spheres: contributions are required, benefits are hoped for, and taxes on benefits may have to be paid. If a worker splits a career between several countries, each of these three spheres is affected. The United States has sought...

The right of legislation in the area of taxation is part of the sovereign right of each Member State, providing that State with autonomy of decision-making as regards its tax policy measures. This autonomy, however, is restricted by EU law in three ways:1. member States are bound by the Four...

This paper addresses agency tensions and conflicts that may emerge between managers (agents) and shareholders (principals) as a result of aggressive tax planning strategies adopted by publicly held corporations. The interactions between corporate governance and taxation are bilateral and...

This paper deals with the consequences of signing the Treaty on the establishment, coordination and governance in the European Union, also known as the "Tax Treaty". Thus, our article presents some general concepts on the relationship between taxation, fiscal policy and the European Union,...

Le Code européen du contribuable est l’une des 34 mesures contenues dans le Plan d'action de la Commission européenne pour lutter contre la fraude et l'évasion fiscales qui a été adopté le 6 décembre 2012. Il s'agit d'une mesure qui pourrait améliorer la perception de l'impôt et...

The “policy-mix” is a relative new concept in research-development and innovation literature and policy. It has been introduced some years ago, as a new model of resources mobilization through the coordination of different policies, having in view the accomplishment of the objective of...

Discussions at the “Freedom of Investment” Roundtables, hosted by the OECD Investment Committee, have stressed that increased investments by foreign State-controlled investors can bring significant benefits to home and host societies, but have also noted that they can raise concerns. This...