World events in the first decade of this century led many to question the state of the international tax regime and the role it could play in solving national fiscal problems. In 2012, leaders of the Group of 20 (G20) set the OECD an ambitious agenda of working out how tax base erosion and...

The proprietary nature of corporate management tax policy and corporate tax return information results in very little information being known about the tax aggressive behaviour of these entities. Despite this lack of inside knowledge, tax scholars have continued to attempt to identify corporate...

As part of the Organisation for Economic Co-operation and Development's Base Erosion and Profit Shifting project, country-by-country reporting (CbCR) has been promoted as a mechanism to enhance transparency with respect to the operations and tax planning activities of large multinational...

Hungary was the first post-socialist country in eastern Europe to adopt a general anti-avoidance rule (GAAR). The original GAAR adopted in 1990, best described as a "form and substance" GAAR, was supplemented by a second GAAR in 1998, best described as a "proper use of rights" GAAR. The tax...

Australian tax laws have contained a general anti-avoidance rule (GAAR) for over a century. The income tax GAAR proved robust for over half a century but ceased to be effective when read down in the 1970s and was replaced in 1981. The current GAAR has been recently amended to include specific...