This article examines the impact of the international tax system on the location decision of a foreign permanent establishment (PE) including cross-border loss relief and activity clauses. Germany, e.g., operates a hybrid system of international taxation, under which foreign income from PEs...

The introduction of a formulaically apportioned common consolidated corporate tax base (CCCTB) could represent a milestone in international taxation. No agreement has yet been reached, however. In contrast, Germany already has a long-standing system that apportions corporate taxes by splitting...

Following the establishment of the Single Supervisory Mechanism (SSM), concerns about having a level playing field become more important due to the heterogeneity in bank taxation rules across Europe: measuring the tax burden can provide a first rough measure of the extent of heterogeneity across...

This article is a reply to Martin Wichmann's reply from a German perspective to John F. Avery Jones's article 'Why Can't the English ... ?', both published in the Bulletin for International Taxation of the International Bureau of Fiscal Documentation (IBFD), 2019 (Volume 73), No. 6/7. It argues...