The OECD Programme of Work on the tax challenges arising from the digitalization of the economy comprises a so-called GloBE (Global Base Erosion) or Pillar Two proposal, consisting of a series of measures aimed at establishing a floor to tax competition by achieving minimum taxation of the...

This article examines the compatibility of the OECD's proposed rules on GloBE (pillar II) with EU law, covering both primary law and secondary law. In addition, it discusses the amendments required by the implementation of this initiative within the internal market. In what concerns...

[EN] “Should I stay or should I go… ”? The implementation of the EU’s internal market, characterized in the Treaty on the functioning of the European Union ( TFUE) as ”an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured”,...

[EN] “Should I stay or should I go… ”? The implementation of the EU’s internal market, characterized in the Treaty on the functioning of the European Union ( TFUE) as ”an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured”,...

This article deals with the decision taken by the Court of Justice of the European Union in of 26 February 2019 in N Luxembourg I et al. (Joined Cases C-115/16, C-118/16, C-119/16 and C-299/16) and T Danmark et al. (Joined Cases C-116/16 and C-117/17).The authors acknowledge that the "Danish...

The issue of base erosion and profit shifting has been on the international policy agenda for several years now. The aim of this paper is to examine how firms adjust their profit shifting mechanisms in a changing institutional environment. In particular, we test whether firms substitute one...

In recent years, profit shifting by multinational companies has generated substantial revenue costs to the U.S. government. The Tax Cuts and Jobs Act (TCJA) changed the climate for profit shifting in several important ways: the lower U.S. corporate rate should lower the incentive to shift...

The main purpose of this book is to promote the dissemination of the basic notions of taxation from a policy, legal and administrative perspective, offering its readers a balanced view of rights and obligations connected with the levying of taxes. The book sets out current principles of taxation...

In 2009, the United Kingdom abolished the taxation of profits earned abroad and introduced a territorial tax system. Under the territorial system, firms have strong incentives to shift profits abroad. Using a difference-in-differences research design, we show that profits of UK subsidiaries in...