We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Tsilly Dagan, GLoBE: The Potential Costs of Cooperation This article argues that the fact that the 2021 global tax deal (focusing on Pillar 2) is cooperative is not in itself proof of the deal…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Reuven Avi-Yonah, Do Intangibles Fit BEFIT? This article argues that the BEFIT formula should not include intangibles because they are subject to manipulation and their value is reflected by other factors in the existing…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Jeroen Lammers & Błażej Kuźniacki, The EU Solidarity Contribution and a More Proportional Alternative: A Study Under EU and International Investment Law This paper reviews the EU Solidarity Contribution that was recently introduced by…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Rachna Matabudul, The Multilateral Instrument in Africa: A Strategic Analysis The Multilateral Instrument (MLI) was launched under Action 15 of the Base Erosion and Profit Shifting (BEPS) Project in November 2016 under the joint…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Stefan Greil, Michael Overesch, Anna Rohlfing-Bastian, Ulrich Schreiber & Caren Sureth-Sloane, Towards an Amended Arm’s Length Principle: Tackling Complexity and Implementing Destination Rules in Transfer Pricing The arm’s length principle (ALP) is the…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Leonie Fischer, Jessica M. Müller & Christoph Spengel, The Distorting Effects of Imputation Systems on Tax Competition in the EU The design of corporate income tax systems and thus the taxation of (cross-border)…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Victoria Perry, Pillar 2, Tax Competition, and Low Income Sub-Saharan African Countries This article explores the implications of Pillar 2 of the G20/OECD Inclusive Framework Blueprint for global tax reform on tax incentives and…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Joachim Englisch, GloBE Rules and Tax Competition This article studies foreseeable effects that a relatively comprehensive implementation of the Pillar 2 GloBE international effective minimum tax would have on international tax competition for investment….
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Brown & G. Jackson, Interpretation of Multi-Lateral Treaties: The Purposive Approach and Multiple Parties Through the Lens of the UK Courts In this article the authors consider how to interpret the multilateral provisions in…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Zhe Chen & Bart Peeters, A Study on the Protection of Taxpayer Rights in an Era of Enhanced Exchange of Information: How Can the Chinese Approach Be Improved? This study explores taxpayer protection under…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Suranjali Tandon, The Need for Global Minimum Tax: Assessing Pillar Two Reform In 2021, the Organisation for Economic Co-operation and Development (OECD) announced its proposal to introduce a global minimum tax. This proposal signals…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Stefanie Geringer, The EU’s Uncoordinated Approach to Tax Avoidance and Tax Abuse in Relation to ‘Uncooperative’ Tax Jurisdictions The European Union (EU)’s external tax policies in relation to ‘uncooperative’ tax jurisdictions are predominantly shaped…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Nevia Čičin-Šain & Joachim Englisch, DAC 7: An Entire New Framework for Joint Audits in the EU: How Do the Taxpayers Fare? Joint audits have the potential to facilitate tax collection and at…
We are happy to inform you that the latest issue of the journal is now available and includes the following contributions: Polyvios Nikolaou, Mandatory Binding Arbitration: Avoiding Stalemates Over the Tax Chessboard The resolution of tax treaty disputes under the Mutual Agreement Procedure (MAP) mechanism is inherently problematic. This article examines how the introduction…
