In the context of the proposed European CCCTB there is clearly a perceived need for the introduction of a common thin capitalization rule. This rule would be aimed at dealing with inbound investment emerging from both third countries, and from Member States opting out of the CCCTB. The principal...

This article presents a new conceptual framework for research into tax fraud and law enforcement. Informed by research approaches from across tax law, public economics, criminology, criminal justice, economics of crime, and regulatory theory, it assesses the effectiveness, and the legitimacy, of...

Tax administration is often perceived as separate from tax policy, and at best as the implementation of tax policy. The aim of this article is to highlight the necessary mutual dependence that exists between tax policy and administration, designated here as tax policy-administration symbiosis....

The aim of this paper is to establish whether VAT place of supply rules are more effective allocation rules than international tax rules currently governing income taxation. This is done through the analysis of the “place where the activity is effectively carried out” (PWAECO) and the...

Similarly to the significant of the concept of permanent establishment (PE) for the purpose of income taxes rules, the relevance of the concept of fixed establishment (FE) for the VAT rules can hardly be overestimated. The term plays a central role, and is consistently relied upon by the...