Volume 44 (2016), Issue 8/9 contains: EDITORIAL: Andreas OESTREICHER, ‘To See or Not to See: That Is Not the Question’ ARTICLES: Georg KOFLER, ‘Some Reflections on the ‘Saving Clause’’ Abstract: Action 6 of the Organization for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting project deals with tax treaty abuse and proposes inter…
Volume 44 (2016) issue 6/7 contains: EDITORIAL: Ana Paula DOURADO, ‘The EU Anti Tax Avoidance Package: Moving Ahead of BEPS?’ ARTICLES: Félix Daniel MARTINEZ LAGUNA, ‘Institutional Hybrid Financial Instruments and Double Non-taxation under Domestic Rules and Tax Treaty Law: The Example of Spain’ Abstract: Attention has been paid to double non-taxation resulting from contractual hybrid…
Volume 44, Issue 5 contains: ARTICLES: Roland ISMER, Sophia PIOTROWSKI, ‘A BIT Too Much: Or How Best to Resolve Tax Treaty Disputes?’ Abstract: State to state disputes under tax treaties are increasingly open for mandatory arbitration when intergovernmental negotiations do not reach a timely agreement. The present contribution seeks to understand this procedure. It also…
Volume 44, Issue 4 contains: ARTICLES: Lisette van der HEL – van DIJK, Menno GRIFFIOEN, ‘Tackling VAT-Fraud in Europe: A Complicated International Puzzle’ Abstract: In Europe, the fight against VAT fraud has attracted a lot of attention since the introduction of the current VAT system. The reason for this is simple: VAT fraud leads to…
Volume 44 (2016) Issue 3 contains: ARTICLES José Manuel Calderón CARRERO, Alberto Quintas SEARA, ‘The Concept of ‘Aggressive Tax Planning’ Launched by the OECD and the EU Commission in the BEPS Era: Redefining the Border between Legitimate and Illegitimate Tax Planning’ Abstract: In recent years, the need to prevent and combat aggressive tax planning has…
Volume 44 (2016) Issue 2 contains: EDITORIAL Dennis WEBER, ‘The New Common Minimum Anti-Abuse Rule in the EU Parent-Subsidiary Directive: Background, Impact, Applicability, Purpose and Effect’ Abstract: Due to an amendment of the Parent-Subsidiary Directive, the EU Member States must include a ‘common minimum anti-abuse rule’ in their legislation for situations that fall under the…
Volume 44 (2016) Issue 1 contains: EDITORIAL Ana Paulo DOURADO, ‘May You Live In Interesting Times’ Abstract: In the current global tax good governance context, exchange of information is one condition for the BEPS initiative to be successful. Action 5 (Counter Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance) foresees mandatory spontaneous…
