Since the turn of the current century, leading transnational organizations and academic scholarship have identified tax competition among countries as one of the scourges of the international tax regime. Both the EU and the OECD have warned that tax competition erodes the tax bases of Member...

Probably the most uncontroversial thing that one can say about international taxation is that it is a mess. Sophisticated planning techniques, which seem beyond the power of taxing authorities to control, enable highly profitable multinational enterprises (MNEs) to pay little or no tax on their...

The issue of corporate residence has recently attracted a great deal of attention in both the popular press and in academic discourse, primarily because of the phenomenon of corporate inversions. The consensus among commentators is that the root of the problem is a flawed definition of corporate...

With the growth of electronic commerce tax authorities were faced with the challenge of applying traditional tax principles, which have been developed in times where business comprised the delivery of physical goods and services were provided in face-to-face transactions, to cross-border...

This Comment evaluates four recent proposals to reform tax laws affecting the financial industry. After introducing the proposals, the author provides a theoretical framework for evaluating them and then relies on this framework to explore the benefits and drawbacks of each. Ultimately, the...

This Note proposes a solution to what has been one of the most vexing problems in state corporate taxation and in multijurisdictional taxation generally: the delineation of the scope of the entity that an individual jurisdiction is entitled to tax. Starting from the observation that the federal...

The reform process for the indirect taxation regime in India has been ongoing for some time, with the prevailing view being that simplification of tax regime and a principle-laden approach was an essential concomitant in the outlook of a developed nation. Much debate has ensued and during the...

Section 11 applies a bracket system to corporations, imposing lower tax rates on lower amounts of corporate income. Similarly, section 1 applies a bracket system to individuals. The bracket system in section 1 is intended to adjust the tax rate to the taxpayer's standard of living. Modest and...

In an earlier article titled as ‘Service Tax on Lawyers: A levy short lived?' [Excise and Customs Reporter Vol. 191(4), pp. 55SF-60SF] I had an occasion to point out that the levy of service tax on individual lawyers was an experiment out of the various experiments conducted by the Government...

The history of ever expanding horizon of service tax law in India has extensive sub-chapters of its own. The levy being unique and unprecedented in the country, the Finance Act, 1994 has made a number of experiments for the levy and collection of service tax from various sectors. Sometimes owing...