Number 6 - 2006 contains the following:
 

In Part 1 of this article, the authors consider the traditional role that the most-favoured-nation (MFN) concept played in respect of trade relations under public international law, analyse the potential basis and relevance of MFN treatment in EC law in a more general perspective, and examine the effect of the MFN concept on direct taxation and, in particular, on tax treaties.

The authors provide a brief description of the 1990 EC Merger Directive and then focus on the 2005 amendments to the Directive.

This article deals with the new issues arising in the EU context regarding controlled foreign company (CFC) regimes in respect of tax arbitrage within the Internal Market and distinguishing this from the concept of tax avoidance, based on the redefinition of the EC law concept of abuse of rights. The article, therefore, analyses the debate at three different levels, i.e. with regard to domestic law, tax treaties (both in Part 1) and EC law, (in Part 2).

The author provides an overview of the Bouanich case.

New biannual section. The author examines the issue of whether or not the International Covenant on Civil and Political Rights applies to legal entities.