its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global …

“Ectopia” is a label given here to a feature of tax law that distinguishes it from most other forms of law. Income tax … law is dislocated from the facts to which it relates. This dislocation leaves a gap, or “ectopia” between tax laws and the … economic facts of the transactions or structures to which it relates. The ectopia of income tax law is pathological, serious …

world where data is the “new oil,” tax advisers are increasingly called on to promote and protect their clients’ interests …An imbalance exists between tax authorities and taxpayers when it comes to the latter’s financial information …. Taxpayers have the information they need to calculate their tax liabilities and file their returns. Tax authorities, on the …

In his David R. Tillinghast Lecture given at NYU in 1998, H. David Rosenbloom presented the tax world with a critical … view as to the existence of an “international tax regime”. Has the world changed since? On the one hand there is a strong … move towards international tax coordination, including multilateral agreements and the creation of new institutions …

This paper investigates the effects of double tax treaties (DTTs) on foreign direct investment (FDI) after controlling … shopping, we calculate the shortest (i.e. the cheapest) tax distance between any two countries allowing the corporate income to … be channelled through intermediate jurisdictions. We differentiate between relevant and neutral DTTs - i.e. tax treaties …

project (BEPS) and its implementation, and; iii) member states' tax treaties between them and with third countries. This study … or third-country investments, and it has done so, e.g., in the Anti-Tax Avoidance Directive (ATAD). This has potential … impact also on tax treaties between the member states and with third countries: Given the supremacy of EU (secondary) law …

Viewing the development of the standard international tax neutrality discussion as being historically fairly limited … reconsidered the classic international tax neutrality theories and challenged their conclusions. I argued that residence … how all international tax neutrality benchmarks can be simultaneously achieved by source-based taxation without the need …

Tax policy in general and international income tax policy in particular has long been a subject of discussion and … argument by tax philosophers, economists, and lawyers. Theories have often been introduced to support the establishment of new … tax systems, to justify existing ones, or to call for changes. Economists introduced “economic efficiency” as a criterion …

To what degree developing countries gain from signing double tax treaties is being hotly debated. In this paper, we … analyze the Austrian tax treaty policy. Combining legal and economic perspectives, we find that developing countries are … likely to expect both positive and negative impacts from signing a double tax treaty (DTT) with Austria. On the one hand, the …