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 Organisation for Economic Co-operation and Development...

International tax law is going through a period ofremarkable change. Trends come and go frequently;however, three trends have been steady and durable inthe last years.[...]

Some consider the issues in the European Court ofJustice’s Lidl Belgium (C-414/06) case to be a questionof symmetry in tax law. Others call the case‘‘Marks & Spencer revisited on the branch level.’’ In fact,both statements are correct. The question is whetherthe country of the head...

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 Such a cause for celebration occurred on May31, 2005, when the BFH repealed its strict view onthe German anti-treaty-shopping rule in the landmarkHilversum...

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...