Taxation has become an indispensable part of modern economic systems worldwide, and there are a wide variety of different tax models with different policies, regulations, and collection systems that governments can choose from. Nations have realized the need to exercise care and caution in...

Much has been said and written about the ‘fiscal behaviour' of multinationals. A tax code of conduct is often mentioned as a 'catch-all solution' for stimulating 'acceptable fiscal behaviour'. Stakeholders increasingly demand fiscal accountability to obtain verifiable and validated credible...

The United States tax classification of a “foundation” created under the laws of a foreign jurisdiction is a complicated matter. “Foundations” are not creatures of common law, but are derived from civil law. The United States follows common law and this body of jurisprudence is more...

This Article discusses the OECD BEPS MLI in respect of its policy to implement equally authoritative English and French texts. It evaluates this choice against the background of the policies implemented in the final clauses of all existing bilateral tax treaties, and proposes possible solutions...

This article discusses how language idiosyncrasies affect the interpretation and application of tax treaties in practice, causing interpretative schisms in the international arena. To illustrate, the interpretation of the permanent home tie-breaker in German tax treaties based on Article 4 of...

This article is a reply to Martin Wichmann's reply from a German perspective to John F. Avery Jones's article 'Why Can't the English ... ?', both published in the Bulletin for International Taxation of the International Bureau of Fiscal Documentation (IBFD), 2019 (Volume 73), No. 6/7. It argues...

The Internet of Things is increasingly delivering high-precision mobility data. This makes it possible to fine-tune the use of scarce mobility goods and services and thus achieve higher system efficiency. In the future, it will be feasible to put a price tag on even the smallest traffic areas...

The last three decades have been marked by a battle with money laundering, tax evasion, and even though not strictly illegal, but no less harmful, tax avoidance after the boom in those legal and accountancy services back in the 1980s. The methods that national, international, and supranational...

As a matter of policy, there is a sound theoretical basis (namely the benefits theory) which justifies source taxation when non-residents conduct business with consumers in the market jurisdiction.This justification has long been recognised from the earliest days of tax theories but more...