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…

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…