Number 4 -2007 contains the following:
 

This article contends that an international tax regime exists, embodied in both the tax treaty network and the domestic tax laws of the major trading nations. The article also contends that the international tax regime is an important part of international law as it evolved in the 20th century - in particular, that parts of international tax law can be seen as customary international law and therefore as binding even in the absence of treaties. The article also explains the basic structure of the international tax regime and its underlying norms and sets out the normative rationale for each. Finally, the article discusses recent challenges to the international tax regime, and argues that the reaction to these challenges by the OECD, the WTO, the European Union and specific tax administrations proves the existence of the international tax regime.

This article examines two important new tax laws passed by the Spanish parliament: a new Income Tax Law (ITL) and the Law for the Prevention of Tax Fraud (LPTF). The ITL is a newly drafted law which modifies the previous law in many points of various significance and affects the basic structure of the personal income tax in two ways in particular: it approximates the tax to the dual model and adopts the classical system of dividend taxation. The ITL also modifies other laws, especially the Corporation Tax Law and the Non-Resident Income Tax Law. The LPTF includes some measures specifically directed against tax fraud, but it also contains many others that are only indirectly related to tax evasion or not at all.

This article summarizes the ECJ's settled case law that finally resulted in the N decision and discusses the consequences of the decision for exit taxes in the European Union.

A new GAAR was enacted in South Africa. This article first summarizes the former GAAR, the related discussion paper and the changes proposed, and discusses the response of the SARS and the Treasury to the proposed changes. The main part of the article examines the new GAAR. The article also considers the new legislation on "reportable arrangements". The Appendix to the article contains the text of the new GAAR.

This article sets out Australia's current approach to determining the territorial source of income, focusing on the operation of the statutory source rules and the guiding principles emerging from the common law. The article also evaluates the effectiveness of Australia's source rules in terms of equity, efficiency and simplicity. The article concludes that Australia's domestic source rules are ripe for reform.