. In other words, increase tax transparency. This Article discusses broad international trends that have been the principal … catalyst for tax transparency measures such as the Foreign Account Tax Compliance Act, the Common Reporting Standard and …An imbalance exists between tax authorities and taxpayers when it comes to the latter’s financial information …

This paper focuses on commenting on two separate aspects: (i) whether the current international tax environment that is …) whether the BEPS Project might actually foster some sort of “International Tax Imperialism.” This term being understood to … mean the exportation of developed countries tax patterns to developing economies in way that favor the former …

This paper discusses the harmful tax practices of multinational enterprises (MNEs) and the fight of international … organizations against them. We focus on the anti-tax base erosion and profit shifting project (anti-BEPS project) of the … adapt their business structures and plans according to new tax regulations, which will also lower their profit levels due to …

its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global …

This study provides an interdisciplinary analysis of firm theory and international tax law, applied within a framework … interpretation of different norms of international tax law correlate over time with different and partial views of the functioning of … multinational enterprises and of their value drivers. Accordingly, international tax law is incoherent or ineffective in key aspects …

Within a close system of legal rules, it is almost impossible to combat the abuse of offshore business and tax haven … international business were fully covered by statutory law, the abusive forms of tax planning may result in eluding laws. The reason … for this is that the taxpayers involved in tax avoidance do not fringe any particular legal provision, although they …

This study provides an interdisciplinary analysis of firm theory and international tax law, applied within a framework … interpretation of different norms of international tax law correlate over time with different and partial views of the functioning of … multinational enterprises and of their value drivers. Accordingly, international tax law is incoherent or ineffective in key aspects …

countries. The variance across transfer pricing systems refers not only to formal tax provisions, but also to practical … requirements and regular actions from authorities, and to governments' openness for discussion of unclear tax positions. Although …