Since the OECD started conceiving and implementing the BEPS project, the major argumentation in favour of the new policies is mainly based on the refrain that everybody should pay their “fair share” of taxes. It is hard to find any publicly available explanation about what exactly lies behind the idea of a “fair share” of…
On May 11th a very interesting conference with the topic “How Source and Residence have Developed: Rethinking the Principles of International Income Taxation” has taken place, in Bergamo, organised by the Department of Law of the University of Bergamo and by the University of Heidelberg. Having not stayed until the discussion, I could not comment…
Economic development has been historically associated with the fulfilment of two major conditions: a) Peace and b) low taxation. Peace was the necessary component for prosperity from the point of view of foreign policy. Empires, kingdoms, duchies, principalities and republics have been prosperous only as long as there has been peace. Low taxation was the…
Cornerstone of modern tax systems is the somehow forgotten axiom that taxpayers need to consent to the taxes imposed by governments. This may sound peculiar in an era where political correctness dictates that certain taxpayers do not pay their “fair (?) share” of taxes, although they do comply to tax laws in force; in this…
Is tax avoidance a bad thing? The international tax community seems recently to adopt an almost unanimous position: Yes, it is supposedly a very bad thing, as it not only reduces public revenue, but also makes taxation “less fair”, since tax-avoiding taxpayers do not pay their “fair share”. It is surprising how unanimous is this…
BEPS-Project? CFC rules and transfer pricing? Treaty abuse and dispute resolution? Why bother for such complicated things? Greece has a “perfect” solution against base erosion and profit shifting through cross-border schemes: It is for this purpose that Greece has imposed since March 21st, 2015, an additional condition for the recognition of any expenses payable to…
