The journalistic scandal that reached the headlines with the iconoclastic expression “LuxLeaks” has raised an EU wide debate about national tax administrations' advance ruling practices and it calls for a need to establish the acceptable boundaries between fair and harmful tax competition in...

This article aims at identifying the most relevant shortcomings of any initiative of fighting against abuse of the right of establishment on the basis of a priori set substance indicators. It does so by reference to the Unshell Directive proposal against the broader background of the need to...

Within the framework of its BEPS initiative, the OECD introduced a requirement for non-public country-by-country reporting (CbCR) applying to multinational companies with revenues above EUR 750m. The reports provide data on the global activities and financial structure of multinationals at a...

Using a large panel dataset on worldwide operations of multinational firms, this paper studies one of the most advocated anti-tax-avoidance measures: Controlled Foreign Corporation rules. By including income of foreign low-tax subsidiaries in the domestic tax base, these rules create incentives...

Tax competition in the European Union is shaped by four partly opposed institutional mechanisms. While market integration and enlargement increase competitive pressure, the tax co-ordination of the Council of Ministers and the tax jurisprudence of the European Court of Justice could potentially...

Different in more ways than it is possible to easily enumerate, the formation of the United States and the European Union (EU) had a striking similarity of purpose: to increase citizens' welfare by uniting a collection of independent states, each with its own politics, culture, and economy. Of...

The planned movement to the origin principle with the cross-border pre-tax system on a full-scale would lead, ceteris paribus, to changes in VAT revenues in the individual EU countries. For instance, the member countries with trade surpluses and higher VAT rates would be significantly better...

The introduction of a Common Consolidated Corporate Tax Base (CCCTB) in the European Union (EU) would substantially change the rules of the game in international taxation. According to the proposal by the European Commission (EC), the profits of a Multinational Enterprise (MNE) would no longer...

Profit shifting of multinational corporations (MNCs) negatively affects citizens, governments as well as other companies in the European Union. This consensus seems to be emerging in spite of the fact that the phenomenon of profit shifting is unobservable directly and therefore only indirect and...

By exploiting country-by-country reports (CBCRs) prepared according to the OECD BEPS Action 13's minimum standards and voluntarily published by multinational corporations (MNCs), we show that the CBCR data can be used to identify how much MNCs pay in taxes and where, as well as how important tax...