The European Union is in the process to establish “public country-by-country reporting” as a new and wide reaching obligation for multinationals to disclose tax-relevant numbers to a global audience, going beyond the OECD consensus which combined cross-border exchange of reports with...

The East African Community (EAC) is working towards establishing deeper integrationbetween its six partner states. The EAC partner states are: Burundi, Kenya, Rwanda,South Sudan, Tanzania and Uganda. This paper analyses the lessons the EuropeanUnion may offer the EAC in guarding against base...

This article aims to examine the arguments and conclusions made by Advocate General Bobek in his Opinion delivered on 14 December 2017 in Hornbach-Baumarkt (C-382/16) and their potential consequences for taxpayers in EU Member States. In particular, it argues that cross-border situations...

This article analyses the ECJ decision in Hornbach-Baumarkt (C-382/16) from 31 May 2018 and its implications for the transfer pricing legislations of EU Member States. First, to argue that cross-border transactions targeted by the arm’s length principle are comparable to purely domestic ones,...

The taxation of dividends is characterized by the fact that the taxable object stems from profits that will usually have already been taxed at the level of the distributing company. If the second layer of taxation at the shareholder level constitutes economic double taxation, to what extent, if...

The taxation of dividends is characterized by the fact that the taxable object stems from profits that will usually have already been taxed at the level of the distributing company. If the second layer of taxation at the shareholder level constitutes economic double taxation, to what extent, if...

This article deals with the decision taken by the Court of Justice of the European Union in September 2014 regarding the compatibility of inheritance taxation with the fundamental freedoms (Commission v. Spain (Case C-127/12) and Commission v. Germany (Case C-211/13)).The authors welcome the...

This article deals with the decision taken by the Court of Justice of the European Union in Sopora (Case C-512/13), which was decided by the Grand Chamber of the ECJ on 24 February 2015. It concerns the question of whether a specific requirement to obtain a tax advantage for foreign (incoming)...

This study was drafted shortly after the announcement of the referendum by which the United Kingdom decided to leave the European Union. In this article, the authors make a comprehensive assessment of what would be the tax consequences attached the decision. The article is of interest not only...

This article examines the decision of the CJEU in Brisal and KBC Finance Ireland (Case C-18/15) of 13 July 2016. Following a Portuguese reference for a preliminary ruling, the Court's decision provides further clarification on the permissibility of withholding taxation within the European Union....