The author addresses the phenomenon of taxable profit shifting operations undertaken by multinationals in response to countries competing for corporate tax bases within the European Union. The central question is whether this might be a relic of the past when the European Commission’s proposal...

In this article, the author focuses on the direct and indirect tax case law of the European Court of Justice and uses this to attempt to determine a uniform interpretation of the principle of the prohibition of the abuse of EU tax law

Evolutionary stability is a necessary condition for imitative dynamics of policy learning and innovation to come to a rest. We apply this concept to profit tax competition in a regime where a common and consolidated profit tax base for multi-jurisdictional firms is divided among governments...

This paper provides a model-based analysis of special tax rules for corporations that invest in stocks of other corporations. To avoid double taxation the returns from such stock investments (dividends and capital gains) are usually tax-exempted or taxed at a reduced tax rate. This allows for...

There are at least two reasons why taxation of corporate groups in Europe calls for reform. Firstly, differences are to be found between the tax treatment of a corporate group and that of a single legal entity. Secondly, foreign subsidiaries are often subject to different tax treatment than...

How should Europe respond to society's calls for a sound and properly functioning corporate tax system for the internal market? With the aim of contributing to the deliberations on this subject, the proposal of the author is for the EU Member States to jump ahead in the debate and remodel the...

FATCA is a US domestic tax policy that requires Foreign Financial Institutions around the world to provide the IRS information regarding their US clients. Recognizing this extraterritorial characteristic and the troubles associated with it, the US Treasury Department developed the...