Single Taxation?

Single Taxation?
This book explores the notion of single taxation by presenting opposing views on this complex topic.

Why this book?

Single taxation has instinctive appeal as a policy goal, but a close examination of this seemingly simple slogan reveals a complex set of issues that do not lead to clear or simple answers. In October 2017, IBFD held a one-day symposium, exploring the notion of single taxation, to celebrate the third year of the Advanced Master’s in International Tax Law Programme offered by IBFD and the University of Amsterdam as a cooperative venture.

This book contains the papers written in connection with this symposium. It starts with the LLM thesis of one of the graduates of the 2016/17 Advanced Master’s Programme, which carries out an in-depth investigation of what single taxation might mean in one common business structure. The remaining contributions follow the format of the symposium, each aspect of the topic being addressed in two papers that were written by leading authors independently of each other. The final two chapters reflect the Oxford-style debate that provided a lively finale to the symposium day.

In offering two views of each segment of the issue, this book is intended to provoke discussion. In particular, it is hoped that it will encourage students of international tax law, of all ages and at all stages of their careers, to question their assumptions and form their own opinions.

Other LLM titles:


Sample excerpt, including table of contents


Daniel M. Berman, Francesco De Lillo, Guilherme Galdino, Eric C.C.M. Kemmeren, Svetislav V. Kostić, Neha Mohan, Luís Flávio Neto, Luís Eduardo Schoueri, Frans Vanistendael, Peter Wattel, Joanna Wheeler, Xu Yan.

Single Taxation?
Chapter 1: In Search of Single Taxation
Chapter 2: Exploring Single Taxation: From Concept to Implementation?
Chapter 3: Single Taxation as a Policy Goal: Controversial Meaning, Lack of Justification and Unfeasibility
Chapter 4: Do Taxpayers Have a Right to Effective International Tax Relief? A Sampling Analysis of the Universe of International Tax Systems
Chapter 5: Do Taxpayers Have a Right to DTR?
Chapter 6: Single Taxation in a Single Market?
Chapter 7: Double (Tax) Jeopardy
Chapter 8: International Single Taxation: A Misguiding Notion
Chapter 9: International Single Taxation: The Holy Grail