International business taxation has become the object of debate in recent years. The allocation of taxing rights between residence and source countries is challenged. Time-honoured rules which address different types of business profits, like sales and services, royalties and interest, in...

Within the European Union, there exists a fundamental tension between the fiscal sovereignty of its Member States, in particular in the field of direct taxation, and the requirements of the Internal Market, which aim at the abolition of any regulatory or fiscal obstacles to cross border movement...

The allocation of risk and of the income from risky investment and activities belongs to the central topics of international tax policy today. This fact is highlighted by the current BEPS initiative of G20 and OECD which casts doubt on the recognition of contractual risk allocation within...