Traditionally, countries impose their corporation tax on an entity-by-entity rather than a group-wide basis. As the taxability of entities, tax bases, and tax rates vary from one country to another, these differences give rise to mismatches, leading to double taxation, but also to non-or almost...

This article forms part of a triptych, each panel of which is independent of but also complements the other two. The theme of the triptych is what measures are possible - and impossible - in combating conduit arrangements under EU law. The first panel was published in EC Tax review 2009/6 and...

This article is the final part of a triptych, each panel of which is independent of but also complements the other two. The theme of the triptych is what measures are possible - and impossible - in combating conduit arrangements under EU law. The first panel was published in EC Tax Review 2009/6...

In 2011, the Dutch television program 'Zembla' reported on the use of the Netherlands tax system in international tax structures. This article analyses some of the claims of this documentary describing the use of (Dutch) conduit companies by foreign MNEs and HNWIs. It will become clear that the...

This article forms part of a triptych, each panel of which is independent but also complements the other two. The theme of the triptych is what measures are possible - and impossible - in combating conduit tax arrangements under EU law. As the use of EU conduit companies to acquire tax benefits...