International tax law is facing a fundamental overhaul. Following an increasing unease among citizens and governments with respect to the way in which multinational companies are taxed on their income, the OECD started its well-known project on 'Base Erosion and Profit Shifting' and 'Aggressive...

The tax aspects of bilateral investment treaties are often overlooked. The aim of the chapter is to provide a comprehensive analysis of the relationship between taxation and bilateral investment treaties in the Czech Republic. A major focus is the attitude taken towards tax matters in the...

With opening of the economy in 1991 and subsequent removal of regulatory and trade barriers, India became an attractive investment (Foreign Direct Investment-FDI) destination. A large number of multinationals have established operations in India to utilise the services of available skilled...

This article examines an influential set of articles, written by Professor John Tiley in the late 1980s, about anti-avoidance doctrines developed by US courts. The trilogy of articles was written for a British audience, as part of Tiley's efforts to resist importation of US doctrines...

This paper sets out the text and translations of over sixty of the world's general anti-avoidance rules. General anti-avoidance rules are found in taxation statutes. Known as “GAARs”, they are perhaps the most intractable of all statutory provisions, challenging alike to policy-makers,...

This article, which is based on the inaugral address given at the IBFD Tax Lecture Series in Beijing, China, examines the basic foundations and nature of income tax law before going on to offer a unifying theory of taxation law. Income tax law is notoriously complex for a range of reasons. One...

“Ectopia” is a label given here to a feature of tax law that distinguishes it from most other forms of law. Income tax law is dislocated from the facts to which it relates. This dislocation leaves a gap, or “ectopia” between tax laws and the economic facts of the transactions or...