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...

The common consolidated corporate tax base has been suggested as a way to curb tax avoidance by allocating profits across borders via a formula. This paper demonstrates that when transfer pricing occurs both for tariff and tax minimization, that moving from separate accounting to formula...

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...

This article discusses the case law of the European Court of Justice concerning the compatibility with EU law of territorial tax incentives adopted by Member States from a legal institutional and policy perspective. The author in particular focuses on the potential justifications under EU...

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...

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...

Water is an exhaustible natural resource. Access to clean, safe and affordable water must be managed nowadays not only to avoid any unnecessary use of water, but also allow for continuous supply of such an important factor of public well-being. In recent years, water-related activities acquired...

This article reviews the main technical and policy problems which the implementation of two formats of comprehensive solutions, discussed in the recent report by the Commission on 'Company Taxation in the Internal market' would require. Both approaches imply the consolidation within the EU of...