Against the backdrop of the debate over the introduction of a fi nancial transaction tax (FTT) in the European Union, this Forum is dedicated to the discussion of issues concerning the implementation and impact of such a tax on the fi nancial sectors of the member states. Dorothea Schäfer...

The relationship between tax authorities and large corporate taxpayers is a concern world-wide as can be seen from the 2008 OECD Study into the Role of Tax Intermediaries. In the United Kingdom, HMRC have been developing a risk rating approach to tax risk management as part of their Review of...

This article deals with sham transactions. It starts off by establishing some basic groundwork on shams, before engaging more specifically with two questions that have recently come to the fore both in cases and in academic debate. The first concerns the relevance of an intention to enforce and...

Transactions designed to avoid statutory provisions bear the legal risk that courts deem them unsuccessful. As this legal risk is a function of the approach courts adopt towards them, identifying and understanding it fully is a sine qua non requirement, without which one simply cannot assess the...