In contrast to the VAT regime, income taxation in the European Union (EU) remains almost fully non-harmonised. A number of factors suggest the possibility that harmonisation of direct taxes in the EU may not be as far-fetched as many believe. The first is the compulsion of mounting economic and...

In contrast to the VAT regime, income taxation in the European Union (EU) remains almost fully non-harmonised. A number of factors suggest the possibility that harmonisation of direct taxes in the EU may not be as far-fetched as many believe. The first is the compulsion of mounting economic and...

In this article, the authors examine a European Commission ruling that classified the U.K. controlled foreign corporation group financing exemptions as illegal state aid and has now been upheld by the General Court of the European Union. They argue that unlike the commission’s previous state...

Over the years, and particularly in the post-global financial crisis era, some harmonization of Member States’ tax policy has increasingly been seen as a task necessarily incidental to the functioning of the single European market. However, since its inception, the E.U. constitution has never...

Widely publicised profit-shifting cases in Europe against multinationals such as Starbucks, Fiat, Apple and Amazon have caught the attention of Australian scholars and tax officials with the revelation of the direct involvement of Australian subsidiaries such as Apple in the arrangements. The...