Taxation inevitably gives rise to tax planning. In the era of globalization, multinationals in particular will (re-)organize their business so as to make an optimal use of international tax sheltering opportunities. In order to curb ‘aggressive' tax arbitrage, all developed jurisdictions rely...

In all Member States of the European Union, tax benefits or tax relief granted in the context of a harmonized energy tax are a frequent phenomenon. Most of those tax expenditure rules have been introduced at the discretion of the Member States, based on the authorizations of Article 5 and 15-19...

Arguably, any tax fairness rule requires an even-handed taxation of taxable persons according to a universal standard of tax equality, or tax equity, rooted in ethical values. In modern civilized societies such values are often enshrined in a nation's constitution. One core concept that that can...

The taxation of dividends is characterized by the fact that the taxable object stems from profits that will usually have already been taxed at the level of the distributing company. If the second layer of taxation at the shareholder level constitutes economic double taxation, to what extent, if...