In the context of the OECD BEPS Plan and the actions undertaken by the European Union to achieve a fair and efficient corporate tax system, the enhancement of dispute resolution mechanisms between tax administrations is practically the only action aimed at boosting taxpayers’ rights, which is...

At a domestic level, dividend tax systems are usually designed to relieve the economic double taxation of corporate profits and are related to the personal taxation of savings income. Increasingly over the last 40 years, however, international considerations have intruded upon domestic tax...

Over time, the use of most favoured nation clauses has seen widespread adoption in double tax treaties, especially in those agreed with developing countries. The use of such clauses, however, does not appear to have been supported frequently by tax policies and/or careful ad hoc analysis, e.g....

This Article compares the ways in which the United States and the European Union limit the ability of state-level entities to subsidize their own residents, whether through direct subsidies or through tax expenditures. It uses four recent charitable giving cases decided by the European Court of...

Although freedom of religion seems, prima facie, to have little relevance to taxation, church taxes raise many interesting legal questions in relation to this human right. In this contribution, the authors identify potential issues linked to the levying of church taxes when taxpayers are...

Transnational tax information cooperation has the crucial role of empowering tax administrations to collect tax revenues in full and on time, thereby narrowing the tax gap created by international evasion and avoidance. However, the adequacy of established transnational tax information exchange...

In this research paper, we attempt to estimate the tax revenues to be gained (or lost) by the South Centre and African Union's Member States under the Amount A and Article 12B regimes. Our analysis relied on sources of information available to private sector researchers but did not involve...

This Article considers the effects of EC law on U.S. tax treaty policy. The discussion is framed by the controversy over the legality of tax treaty limitation on benefits clauses (LOBs) in the wake of recent ECJ decisions, and it argues that U.S. tax treaty policy is on a collision course with...