This is a short tale of those who play the gameand those who don’t. The name of the game is‘‘function shifting,’’ often played moderately, sometimesaggressively, by multinational corporations,but always under the alert eyes of the tax authorities.Those who play the game argue that...

The northern lights are a spectacular sight andone of the features that make the Nordic countriesof Norway, Sweden, and Finland special. Anotherunique aspect of those countries is the waythey tax labor and capital income. In the 1990s, theywere the first countries that treated capital incomemore...

You can’t blame everything on the Romans. Eventhough they introduced the legal framework ofpartnerships and corporations in Germany and farbeyond, the reason why the taxation of partnershipsis so complex is not their fault. Put simply, onceindividuals with different characteristics are...

[...]Drafting antiavoidance legislation is one of thebiggest challenges of modern tax law. The English,German, and French languages have long had thesaying ‘‘Don’t throw the baby out with the bathwater.’’ Only those with a sharp tongue would evercontend that this saying serves as a...

Time and again, a decision of the German FederalTax Court (Bundesfinanzhof, or BFH)makes an international tax planner’s heart beatfaster. Such a cause for celebration occurred on May31, 2005, when the BFH repealed its strict view onthe German anti-treaty-shopping rule in the landmarkHilversum...

[...]Major industrial countries tend to follow themainstream, cutting corporate tax rates and simultaneouslybroadening the tax base. Countries on themainstream path also want to tighten antiabuseprovisions such as the thin cap rules and, in Germany,the anti-treaty-shopping rules, described inour...

Being freshmen in this club of TNI correspondents,we promise not to squander readers’precious time. Instead, we are dedicated to presentingtopics that make our columns worthwhile reading.Our focus will be on European and internationaltax law issues analyzed from a German perspective,yet...