After specifying the nature of taxes as a coercive power application and as a public authority expression, this article examines the way economic tax theories acknowledge these essential fiscal dimensions. We first consider the particular position of the old French public financial economics;...

Actual fiscal structures' functioning is greatly constrained by some distortions, such as efficiency costs, due to the coercitive nature of tax collection. The mainstream optimal taxation literature ignores, however, the incurring tax system costs. Given these costs and in presence of fiscal...

Die Beratung der Entwicklungsländer mit Blick auf die Gestaltung der Steuerpolitik und der Erhebung der öffentlichen Einnahmen ist Gegenstand der Aktivitäten internationaler Finanzierungseinrichtungen. Die Notwendigkeit einer Unterstützung auf diesem Gebiet wird hergeleitet aus der...

The U.S. international income tax rules, which govern the U.S. tax treatment of multinational companies, employ five key concepts: corporate residence, source of income, foreign tax credits with limits, deferral, and subpart F. This paper, which is a draft version of chapter 2 of a book in...

This paper discusses tax policy measures to reduce corporate tax avoidance by extending taxation in the source country without imposing double taxation. We focus on four options: Bilaterally restricting interest and royalty deductibility, introducing an inverted tax credit system, levying...

This Handbook entry presents a conceptual, normative overview of the subject of taxation. It emphasizes the relationships among the main functions of taxation -- notably, raising revenue, redistributing income, and correcting externalities -- and the mapping between these functions and various...

The article assesses the impact of a Common Corporate Tax Base (CCTB) as promoted by the European Commission and the related Working Groups on the effective tax burdens of companies in all 27 EU member states. The results shall help to evaluate the economic consequences of introducing a...

This case was an adapted version of a tax case heard in U.S. Federal District Court and the US Court of Appeals. The case involved a partnership set-up by a large US corporation with its own subsidiaries as managing partners and foreign partners as outside investors. The formation of the...

It can be observed, that the member states of the European Union were guided to implement some reforms in the domain of fiscal politics, the aim of which would constitute in fighting and eliminating the "damaging" fiscal competition, of the differences regarding to indirect fiscality, etc....