The OECD seeks to align transfer pricing and profit taxation with value creation but fails to provide a clear definition. This paper argues that value creation requires international cooperation and that the profit tax base should therefore be allocated according to standards commonly considered...

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 reviews the major elements of the enterprise income tax (EIT) system in China and examines the dynamic relationship between international norms and the local Chinese context. After some introductory remarks, the article discusses the fundamental principles, concepts and structural...

This paper deals with trusts that are established in New Zealand or Australia, with locally resident trustees, but having foreign settlors and foreign-source income. For purposes of source country tax, it may be relevant whether there is an agreement to minimise double taxation between New...

One of the main features of the common consolidated corporate tax base (CCCTB) Draft Directive, the formulary apportionment of the consolidated group income, leads to a significant change in corporate income taxation paradigms. Currently, corporations are taxed on a separate entity basis using...

This article assesses the impact of a Common Corporate Tax Base (CCTB) as promoted by the European Commission and the related working groups on the effective tax burdens of companies in all 27 EU Member States. The results shall help to evaluate the economic consequences of introducing a...

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...

It is widespread practice around the world that corporate entities pay taxes to the country where they are formally registered and to the country in whose territory they generate income. While the former is generally known as the "country of residence" the latter is usually referred to as the...