To operate efficiently and effectively revenue authorities require discretion, but processes must be in place to keep discretion in check. This delicate balancing act takes place against the background of a more general constitutional framework. This chapter outlines the unique features of the...

The most significant problems with the existing system for taxing the profit of multinational companies stem from two related sources. First, the underlying “1920s compromise” for allocating the rights to tax profit between countries is both inappropriate and increasingly hard to implement...

This book chapter discusses the background to the UK General Anti-Avoidance Rule, analyses the wording of the legislation and looks at its relationship with double taxation treaties and EU and OECD developments