This paper outlines the core issues of the introduction of a new PE nexus based on digital presence. It puts forward its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global economy. Our proposal of a new PE nexus based on digital...

If interpreted in a strict legal sense, beneficial ownership rules in tax treaties would have no effect on conduit companies because companies at law own their property and income beneficially. Conversely, a company can never own anything in a substantive sense because economically a company is...

Some scientists and authorities are arguing that tariffs are growing more and more unimportant since eight GATT/WTO-Tariff-Rounds have resulted in tremendous reductions of the original tariff rates in the late 1940ies. The Non-Tariff-Measures however are gaining more importance. A...

New gaps are emerging worldwide in all customs tariffs that are using the Harmonized Commodity Description and Coding System (Harmonized System Convention) following the technical revision as of 1 January 2007. Thirty-four headings are not in use for the next four to five years. This...

More and more countries and economic regions are applying the Harmonized Commodity Description and Coding System (Harmonized System Convention). This paper examines in the update 2012 the new countries which are using the worldwide uniform language of trade.