The paper explores the criteria used by the ECJ in different cross-border activities and transactions to determine whether two situations are comparable either from the perspective of the destination/host country (inbound comparables) or from the perspective of the origin/home country (outbound...

This article suggests that the judicial reasoning adopted within judicial trends developed at national level has been used in shaping evolving perspectives about the concept of permanent establishment adopted in the OECD Model. The article strives to achieve fuller comprehension of the issues by...

The transfer of intellectual property from a higher-tax country where R&D takes place to a lower-tax country facilitates the phenomenon denominated “base erosion and profit shifting” (BEPS) and this generates a flow of the remuneration of intangibles from high-tax countries to low-tax...

This Article endeavors to broaden the analysis of available policy tools to address the problems created by financial crises and discusses how, in addition to direct regulation, certain tax measures having a regulatory nature may operate to address the so-called “negative externalities”...

Migration has become an increasingly important phenomenon for societies, especially given its highly controversial political dimension. The complexity of the migrant integration process and its many varieties present challenges to policymakers who need high-quality information on which to base...

Tax departments and their external advisors are increasingly required to deal with the tax law of foreign jurisdictions. This practical new guide is the first to provide a comparative approach to help you understand tax law interpretation in economies engaged in cross-border investment on a...

While its importance in domestic law has long been acknowledged, transparency has remained largely unexplored in international law. This chapter is included in a deeper study of transparency issues in the key areas such as international economic law, environmental law, human rights law and...