The interaction between tax administration, discretion and legitimate expectation has been widely explored. However, the subject has traditionally been approached from the perspective of legality and deeply focused, normatively, on how courts adjudicate cases bordering on the frustration of...

There is a global rush to tax the digital economy. As at June 2020, more than a hundred countries have formulated or adopted unilateral measures towards that objective. Most of these domestic measures are in the incubator, as countries concurrently explore multilateral options to find a...