This paper describes the main anti-avoidance rules against international tax planning by multinational enterprises in OECD and G20 countries. Building on this information and on previous classification efforts in the literature, a new classification of anti-avoidance strength is compiled. It...

Die Arbeiten an der Gemeinsamen konsolidierten Körperschaftsteuer-Bemessungsgrundlage GKKB gehen weiter. Allerdings dient der am 28. Januar 2016 von der Kommission veröffentlichte Richtlinienentwurf primär der Einschränkung von als unerwünscht angesehenen Steuergestaltungen. Das...

The trust is the most useful device that New Zealand offers to non-residents in the field of international tax planning. So long as settlors, beneficiaries, and income are all foreign the trust is unlikely to attract New Zealand tax. The residence of the trustee has no effect on the tax benefits...

The purpose of this article is to demonstrate that the introduction of legal definition of aggressive tax planning (ATP) together with anti-ATP rules by the European Commission under the Securing the Activity Framework of Enablers (SAFE) initiative is an example of legislative inflation of the...

Tax planning with intangibles has become one of the most popular and most vividly debated topics in international taxation. We incorporate various intellectual property (IP) tax planning models into forward-looking measures of effective tax rates, namely the disposal of intangibles to low-tax...

This paper investigates how decision biases affect individuals' tax decisions. We conduct four laboratory experiments with 303 students and 62 experienced tax professionals and find a systematic tax-rate bias in decisions under time constraints. More specifically, decision makers overestimate...

Tax uncertainty often negatively affects investment. Advance tax rulings (ATRs) are commonly used as a measure to provide tax certainty. Rulings are currently controversially discussed in the context of tax planning activities of multinational firms (Luxembourg Leaks). We analyze ATRs as tax...

To a large extent, the body of research that looks at individuals’ compliance with the law focuses on the dichotomy between compliance as rule-following and noncompliance as rule-breaking. However, a fascinating case of noncompliance is that where individuals selectively follow existing rules...