Complaints in society about how multinationals pay corporate tax are familiar. Multinationals seem able to arrange their affairs in a way that allows them to avoid contributing their fair share. Governments help them to attract investment. Workers and customers, meanwhile, face ever-increasing...

The international corporate income and capital gains tax (CGT) systems of basically all modern nation states share a common objective. All seek to effectively ‘capture' multinational enterprises (‘MNEs') that are economically present within the respective taxing state's geographical borders...

Today we live in a globalizing economy: national open markets are steadily developing towards a global market. Within the European Union, the internal market without internal frontiers has been established. However, the fiscal sovereignty of nation states remains limited to economic activities...

In this article, the author examines, through numerical examples, the effects would EU Member States subject taxpayers – both residents and non-residents – deriving income from domestic sources, to unlimited income taxation whilst granting double tax relief for foreign income under a...

In this article, the author examines, through numerical examples, the effects would EU Member States subject taxpayers – both residents and non-residents – deriving income from domestic sources, to unlimited income taxation whilst granting double tax relief for foreign income under a...

The paper provides an analysis of the key practical issues to eliminate double taxation of business income in the Netherlands. Both the methods for relieving juridical double taxation and the methods for relieving economical double taxation (e.g. participation exemption regime) are adressed

In this article, the authors discuss the approach that the Court of Justice of the European Union (CJEU) adopts in deciding which of the European treaty freedoms apply to third country situations. On 13 November 2012 the CJEU delivered a landmark ruling on this matter in the Test Claimants in...

The OECD is holding public consultations on 13 and 14 March 2019 on the challenges facing countries' corporate tax systems as a result of the ever-increasing digitalisation of the economy. As part of these consultations, a document listing the problems at stake and suggestions for possible...

This paper elaborates on current and emerging issues involving the operation of the concept of permanent establishment (PE) in the national tax system and double tax treaty system of the Netherlands. The paper was written as a contribution (country report) to the seminar “New Trends in the...