World Tax Journal - All Articles
[30 July 2020] - International - Profit Allocation within MNEs in Light of the Ongoing Digital Debate on Pillar I – A “2020 Compromise”?
[30 July 2020] - European Union/International - GloBE and EU Law: Assessing the Compatibility of the OECD’s Pillar II Initiative on a Minimum Effective Tax Rate with EU Law and Implementing It within the Internal Market
[23 June 2020] - International - Scaling Back Tax Preferences on Artificial Intelligence-Driven Automation: Back to Neutral?
[9 June 2020] - International/OECD/G20 - GloBE Proposal and Possible Carve-Outs: Is There a Future for Preferential Tax Regimes?
[4 May 2020] - OECD/International - Taxpayers’ Right of Defence in the International Context: The Case of Exchange of Tax Information and a Proposal for the “English” Wednesbury Doctrine as the New OECD (BEPS) Standard
[1 May 2020] - International - Legitimacy in International Tax Law-Making: Can the OECD Remain the Guardian of Open Tax Norms?
[2 April 2020] - European Union/International - Limitation of Holding Structures for Intra-EU Dividends: An End to Tax Avoidance?
[31 March 2020] - India/United Kingdom/United States/European Union/International - Critical Analysis of the Principal Purpose Test and the Limitation on Benefits Rule: A World Divided but It Takes Two to Tango
[28 January 2020] - European Union/International - On the Future of Business Income Taxation in Europe
[22 January 2020] - Africa/Developing Countries/OECD/UN/International - Curtailing BEPS through Enforcing Corporate Transparency: The Challenges of Implementing Country-by-Country Reporting in Developing Countries and the Case for Making Public Country-by-Country Reporting Mandatory
[9 January 2020] - European Union/International - Danish Cases on the Use of Holding Companies for Cross-Border Dividends and Interest – A New Test to Disentangle Abuse from Real Economic Activity?
[7 January 2020] - China/United Kingdom/United States/European Union/International - Protected Tax Havens: Cornering the Market through International Reform?
[18 December 2019] - G20/OECD/International - Institutional and Structural Legitimacy Deficits in the International Tax Regime
[5 December 2019] - OECD/International - Simplifying the Transfer Pricing Analysis: An Illusory Chimaera or a Realistic Ambition?
[11 November 2019] - International - Transfer Pricing for Digital Business Models: Early Evidence of Challenges and Options for Reform
[20 September 2019] - United States/EEA/European Union/G20/OECD/International - International Effective Minimum Taxation – The GLOBE Proposal
[15 August 2019] - G20/OECD/International - Rethinking the Arm’s Length Principle and Its Impact on the IP Licence Model after OECD/G20 BEPS Actions 8-10: Nothing Changed But the Change?
[7 August 2019] - OECD/International - The Single Tax Principle: Fiction or Reality in a Non-Comprehensive International Tax Regime?
[6 August 2019] - G20/OECD/International - Allocation of the Taxing Right to Payments for Cloud Computing-as-a-Service
[30 July 2019] - European Union/International - Assessment of the Interest Barrier Rule of Article 4 of the EU Anti-Tax Avoidance Directive for a Sample of European Firms
[25 April 2019] - OECD/UN/International - In Search of the Digital Nomad – Rethinking the Taxation of Employment Income under Tax Treaties
[2 April 2019] - European Union/International - Citizenship and Tax
[1 April 2019] - OECD/International - Five Core Problems in the Attribution of Profits to Permanent Establishments
[6 March 2019] - Canada/South Africa/East African Community/Africa/International - Designing a General Anti-Avoidance Rule for the East African Community – A Comparative Analysis
[21 January 2019] - United Kingdom/OECD/International - Simulating Tax Minimization Strategies of Multinationals: Evaluating the Effectiveness of Changes in the United Kingdom’s Corporate Interest Deductibility Rules
[21 January 2019] - OECD/International - The Meaning of the Principal Purpose Test: One Ring to Bind Them All?
[18 January 2019] - European Union/International - New Mandatory Disclosure Rules for Tax Intermediaries and Taxpayers in the European Union – Another “Bite” into the Rights of the Taxpayer?
[17 January 2019] - OECD/International - A Deconstruction of the Principal Purposes Test
[22 October 2018] - United States/European Union/International - Joint Audits: Applicable Law and Taxpayer Rights
[16 October 2018] - European Union/OECD/International - Fairness and International Taxation: Star-Crossed Lovers?
[19 September 2018] - OECD/International - Reflections on the Fight against Aggressive Tax Planning (When the Law Is Silent)
[7 September 2018] - OECD/International - What Is Really Wrong with Global Tax Governance and How to Properly Fix It
[6 July 2018] - Australia/Belgium/Canada/Germany/United Kingdom/United States/OECD/International - Confronting Conflicts of Qualification in Tax Treaty Law: The Principle of Common Interpretation and the New Approach Revisited
[29 June 2018] - European Union/International - VAT and the Sharing Economy
[26 June 2018] - OECD/International - The Arm’s Length Standard and Tax Justice: Reflections on the Present and the Future of Transfer Pricing
[22 May 2018] - China (People's Rep.)/G20/OECD/International - The Convergence and Divergence between China’s Implementation and OECD/G20 BEPS Minimum Standards
[23 March 2018] - European Union/International - Addressing the Debt-Equity Bias within a Common Consolidated Corporate Tax Base (CCCTB) – Possibilities, Impact on Effective Tax Rates and Revenue Neutrality
[15 March 2018] - Brazil/Dominican Republic/United States/OECD/International - Back to Grass Roots: The Arm’s Length Standard, Comparability and Transparency – Some Perspectives from the Emerging World
[15 March 2018] - European Union/OECD/International - The Role of the Subjective Element in Tax Abuse and Aggressive Tax Planning
[12 March 2018] - OECD/International - The Principal Purpose Test (PPT) in BEPS Action 6 and the MLI: Exploring Challenges Arising from Its Legal Implementation and Practical Application
[10 January 2018] - Belgium/Canada/Netherlands/United States/International - Is Mediation the Panacea to the Profusion of Tax Disputes?
[7 December 2017] - United Kingdom/European Union/WTO/International - Possible Consequences of Brexit in the Area of Indirect Taxation: Why Prime Minister May Talks about a Hard Brexit, but Really Needs a Soft Brexit!
[5 December 2017] - European Union/International - The Fragmentation of Taxpayers’ Rights in International Dispute Resolution Settings: Healing Anxieties through Judicial Dialogue
[15 November 2017] - International - The Ombudsman and the Process of Resolution of International Tax Disputes – Protecting the “Invisible Party” to the MAP
[13 November 2017] - Controlled Foreign Corporations as Fiscally Transparent Entities. The Application of CFC Rules in Tax Treaties
[6 November 2017] - International - For the Good of the Game? A Comparison of the Taxation of Sportspersons and Sports Organizations outside of and during Major Sporting Events
[19 October 2017] - Africa/East African Community/European Union/International - How Can the East African Community Guard Against Base Erosion and Profit Shifting While Working Towards Deeper Integration? Lessons from the European Union
[28 September 2017] - European Union/International - Tax Competition and Tax Coordination in Aggressive Tax Planning: A False Dichotomy
[4 August 2017] - The Right to Be Informed: The Parallel between Criminal Law and Tax Law, with Special Emphasis on Cross-Border Situations
[3 August 2017] - The Impact and Role of Indirect Taxes Surrounding the Aviation Sector in Mitigating Climate Change: A Legal and Economic Analysis
[3 August 2017] - Why Corporate Taxation Should Mean Source Taxation: A Response to the OECD's Actions against Base Erosion and Profit Shifting
[3 August 2017] - Implementation v. Adaptation: BEPS in Latin America through the Lens of the ILADT Model
[6 April 2017] - Abuse and Aggressive Tax Planning: Between OECD and EU Initiatives – The Dividing Line between Intended and Unintended Double Non-Taxation
[4 April 2017] - Taxing Robots? From the Emergence of an Electronic Ability to Pay to a Tax on Robots or the Use of Robots
[4 April 2017] - Profit Attribution to Dependent Agent Permanent Establishments in a Post-BEPS Era
[7 February 2017] - Tax Confidentiality: A Legislative Proposal at National Level
[1 February 2017] - International Taxation in the Digital Economy: Challenge Accepted?
[25 January 2017] - International Profit Allocation, Intangibles and Sales-Based Transactional Profit Split
[3 January 2017] - Tax Abuse and Aggressive Tax Planning in the BEPS Era: How EU Law and the OECD Are Establishing a Unifying Conceptual Framework in International Tax Law, despite Linguistic Discrepancies
[7 November 2016] - References to the OECD Commentaries in Tax Treaties: A Steady March from “Soft” Law to “Hard” Law?
[20 September 2016] - “Visible, Though Not Visible in Itself”. Transparency at the Crossroads of International Financial Regulation and International Taxation
[13 September 2016] - The Multilateral Tax Instrument and Its Relationship with Tax Treaties
[30 August 2016] - Tax Residence of Individuals within the European Union: Finding New Solutions to Old Problems
[29 August 2016] - Joint Tax Audits: Which Countries May Benefit Most?
[15 June 2016] - G20/OECD/International - Multinational Firm Theory and International Tax Law: Seeking Coherence
[8 June 2016] - Asia-Pacific/International - Taxing Investments in the Asia-Pacific Region: The Importance of Cross-Border Taxation and Fiscal Incentives
[3 June 2016] - European Union/International - The 21st Century Multilateralism in International Taxation: The Emperor’s New Clothes?
[19 April 2016] - Australia/Canada/United Kingdom/United States/International - Sovereign Immunity and Source State Taxation of Sovereign Wealth Funds: Is It Time to Re-Evaluate?
[23 February 2016] - Financial Transaction Tax: An Eleven-Point Analysis of Transaction Taxes Across Member States
[17 February 2016] - Improving the Chinese General Anti-Avoidance Rule: A Comparative and Functional Approach
[12 January 2016] - Hybrid Mismatch Arrangements – A Myth or a Problem That Still Exists?
[28 December 2015] - Market Infrastructure Regulation and the Financial Transaction Tax
[12 October 2015] - A Utility-Based Explanation of Tax Asymmetries
[6 October 2015] - Legitimacy and the Making of International Tax Law: The Challenges of Multilateralism
[17 September 2015] - The Taxation of Technical Services under the United Nations Model Double Taxation Convention: A Rushed – Yet Appropriate – Proposal for (Developing) Countries?
[24 July 2015] - The Arm’s Length Comparable in Transfer Pricing: A Search for an “Actual” or a “Hypothetical” Transaction?
[29 June 2015] - The Impact of the International Tax System of the Home Country on the Location Decision of a Foreign Permanent Establishment: The Case of Germany
[24 June 2015] - Intergovernmental Agreements and the Implementation of FATCA in Europe
[11 June 2015] - Sharing the Benefits of the EU’s Common Consolidated Corporate Tax Base within Corporate Groups
[27 March 2015] - Innovation through R&D Tax Incentives: Some Ideas for a Fair and Transparent Tax Policy
[25 February 2015] - Exposing Unaddressed Issues in the OECD’s BEPS Project: What About the Roles and Implications of Contract Interpretation Law and Private International Law in the Transfer Pricing Arm’s Length Comparability Analysis?
[13 February 2015] - Tax Treaty Override and the Need for Coordination between Legal Systems: Safeguarding the Effectiveness of International Law
[13 November 2014] - An Economic Perspective on Double Tax Treaties with(in) Developing Countries
[14 October 2014] - Tax Incentives and Territoriality within the European Union: Balancing the Internal Market with the Tax Sovereignty of Member States
[10 October 2014] - The Origins of Article 5(5) and 5(6) of the OECD Model
[9 October 2014] - Transfer Pricing, Integration and Synergy Intangibles: A Consensus Approach to the Arm’s Length Standard
[1 July 2014] - Tax Incentives, Tax Expenditures Theories in R&D: The Case of Sweden
[1 July 2014] - Attribution of Functions and Profits to a Dependent Agent PE: Different Arm’s Length Principles under Articles 7(2) and 9?
[23 June 2014] - Tax Treaty Treatment of Dividend Related Payments under Share Loan Agreements
[4 February 2014] - BEPS: An Interim Evaluation
[4 February 2014] - Coordinating the Action of Regional and Global Players during the Shift from Bilateralism to Multilateralism in International Tax Law
[27 January 2014] - Intra-Group Debt at the Crossroads: Stand-Alone versus Worldwide Approach
[16 January 2014] - A Computational Legal Analysis of Acte Clair Rules of EU Law in the Field of Direct Taxes
[1 October 2013] - The Long March of International Taxation towards a Global Tax Legal Order
[26 September 2013] - Profit Shifting and “Aggressive” Tax Planning by Multinational Firms: Issues and Options for Reform
[24 September 2013] - Taxing Capital Income in Emerging Countries: Will FATCA Open the Door?
[23 September 2013] - Stamp, Seligman and the Drafting of the 1923 Experts’ Report on Double Taxation
[13 June 2013] - Editorial
[5 June 2013] - International Taxation of Directors’ Fees: Article 16 of the OECD Model or How To Reconcile Disagreement among Neighbours
[3 June 2013] - Automatic Information Exchange versus the Withholding Tax Regime Globalization and Increasing Sovereignty Conflicts in International Taxation
[8 May 2013] - Articles 24(4) and 24(5) of the OECD Model Applied to Domestic Thin Capitalization Rules
[18 February 2013] - Capital Gains: The History of the Principle of Symmetry, the Internal Order of Article 13 and the Dynamic Interpretation of the Changes in the 2010 Commentary on “Forming Part” and “Effectively Connected”
[11 February 2013] - Freedom of Religion and Church Taxes in Europe
[8 February 2013] - European Tax Controversies: A British-Dutch Debate: Back to Basics and Is the ECJ Consistent?
[7 February 2013] - Forum: Interaction of State Aid, Free Movement, Policy Competition and Abuse Control in Direct Tax Matters
[11 October 2012] - Inheritance Tax and Valuation
[11 October 2012] - The Effects of Value Added Tax (VAT) on the Rate of Government Growth: An OECD Panel Study
[1 October 2012] - The Definition and Ownership of Intangibles: Inside the Box? Outside the Box? What is the Box?
[26 September 2012] - A Common Corporate Tax Base for Europe: An Impact Assessment of the Draft Council Directive on a CC(C)TB
[26 September 2012] - Tax Administration versus Taxpayer – A New Deal?
[25 September 2012] - Editorial
[30 May 2012] - Transnational Tax Information Exchange Networks: Steps towards a Globalized, Legitimate Tax Administration
[21 May 2012] - Proposal for an Enhanced CCTB as Alternative to a CCCTB with Formulary Apportionment
[7 May 2012] - Using EU Law To Interpret Undefined Tax Treaty Terms: Article 31(3)(c) of the Vienna Convention on the Law of Treaties and Article 3(2) of the OECD Model Convention
[25 January 2012] - The Distinction between Direct and General Costs with Regard to the Deduction of Input VAT – The Case of Acquisition, Holding and Sale of Shares
[25 January 2012] - The European Company (Societas Europaea – SE) Caught In Between Cross-Border Mobility and Lock-In Effect – An Empirical Analysis on the Influence of Exit Taxation upon Cross-Border Mergers and Seat Location Decisions
[25 January 2012] - Unsuitable EU VAT Place of Supply Rules for Electronic Services - Proposal for an Alternative Approach
[25 January 2012] - Unsuitable EU VAT Place of Supply Rules for Electronic Services - Proposal for an Alternative Approach
[31 October 2011] - Fiscal Federalism in Chinese Taxation
[23 September 2011] - Federalism and the Euro Crisis
[5 September 2011] - Formulary Apportionment – Myths and Prospects
[27 May 2011] - The Missing Keystone of Income Tax Treaties
[27 May 2011] - Art. 24(5) of the OECD Model in Relation to Intra-Group Transfers of Assets and Profits and Losses
[18 May 2011] - The Economic Unit of Effective Tax Rates
[9 February 2011] - The Attribution of Income in the Netherlands and the United Kingdom
[20 December 2010] - How to Reform Taxation of Corporate Groups in Europe
[20 September 2010] - International Tax Coordination for a Second-Best World (Part III)
[9 September 2010] - Taxing International Business Income: Hard-Boiled Wonderland and the End of the World
[9 September 2010] - The Taxation of Foreign Investment Funds: A Comparative Review of Selected Aspects of the Rules of Germany and New Zealand
[3 September 2010] - Tax Treatment of Team Performances under Art. 17 of the OECD Model Convention
[20 May 2010] - Taxation and Non-Discrimination: A Reconsideration
[20 May 2010] - Non-Residents – Personal Allowances, Deduction of Personal Expenses and Tax Rates
[20 May 2010] - Non-Discrimination and the Taxation of Cross-Border Dividends
[10 May 2010] - Tax Discrimination and Capital Neutrality
[7 May 2010] - What Can Trade Teach Tax? Examining Reform Options for Art. 24 (Non-Discrimination) of the OECD Model
[7 May 2010] - Taxation and Non-Discrimination, A Reconsideration of Withholding Taxes in the OECD
[22 January 2010] - International Tax Coordination for a Second-Best World (Part II)
[21 January 2010] - Is the Wealth Tax Harmful to Economic Growth?
[20 January 2010] - Between Formulary Apportionment and the OECD Guidelines: A Proposal for Reconciliation
[15 January 2010] - Beneficial Ownership: Current Trends
[27 October 2009] - Why a World Tax Journal now?
[6 October 2009] - The Definitions of Dividends and Interest in the OECD Model: Something Lost in Translation?
[5 October 2009] - Common Corporate Tax Base and Effective Tax Burdens in the EU Member States
[2 October 2009] - International Tax Coordination for a Second-Best World (Part I)
[1 October 2009] - Exit Taxes in Norway
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