Tax avoidance by multinational enterprises (MNEs) is a global problem. Most crossborder trade occurs within MNEs, susceptible to abuse of gaps and loopholes in domestic and international tax law that allow “profit shifting” between fiscal jurisdictions in order to reduce corporate tax...

The fact that direct taxation in the EU is still not integrated, and maybe will never be fully integrated, is one of the major obstacles for the 'single market'. The essay describes the history of attempts (and failures) to harmonize direct taxation in the EU - fully or partly. It concentrate on...

This paper explores how the Common Consolidated Corporate Tax Base (CCCTB) Directive Proposal under the EU law should be designed to allocate cross-border income earned from MNE taxpayers of the transportation industry.The transportation activity is mobile in nature, and thus creates the...

Abstract: Die Besteuerung grenzüberschreitend tätiger, verbundener Unternehmen in der Europäischen Union befindet sich im Umbruch. Die vorherrschenden Regelungen zur Gruppenbesteuerung in den Mitgliedstaaten sind derzeit noch überwiegend auf national tätige, verbundene Unternehmen...

This paper seeks to contribute to the current debate on EU-wide corporate taxation, steered by the impending Proposal by the European Commission on a new framework for the taxation of income of businesses in Europe. The objective of this paper is to verify whether the inclusion of intangible...

The tax neutrality principle was defined as a tax system not influencing the taxpayers’ business decisions. Economists usually use ‘the no tax world’ as the baseline to decide if a specific tax measure is ‘neutral. If a taxpayer’s reaction to a specific tax is the same as if there is...

The European Commission is currently working on a legislative draft to harmonise corporate income tax provisions for multinational groups of companies throughout the European Union. For that purpose the European Commission has installed a working group with the mission to draft a set of rules...

The European Commission proposed to replace the currently existing Separate Accounting by an EU-wide tax system based on a Common Consolidated Corporate Tax Base (CCCTB). Besides the CCCTB, there is an alternative tax reform proposal, the European Tax Allocation System (ETAS). In a dynamic...