European law plays a major role in implementing the OECD/G20 BEPS Action Plan. This role influences the interpretation of primary and secondary European law, which the author concludes is not easy to defend as the fiscal purpose of the BEPS actions conflicts with the liberating forces of the European Union’s Internal Market.
{"title":"Interpreting European Law in the Light of the OECD/G20 Base Erosion and Profit Shifting Action Plan","authors":"W. Schön","doi":"10.59403/3202szr","DOIUrl":"https://doi.org/10.59403/3202szr","url":null,"abstract":"European law plays a major role in implementing the OECD/G20 BEPS Action Plan. This role influences the interpretation of primary and secondary European law, which the author concludes is not easy to defend as the fiscal purpose of the BEPS actions conflicts with the liberating forces of the European Union’s Internal Market.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":" 41","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-03-18","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141221893","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
In its analysis, this article distinguishes between domestic anti-avoidance rules that counteract treaty abuse and those that thwart abuse of domestic law. The authors conclude that conflicts could arise with tax treaties. States should employ a provision that authorizes the application of these rules to prevent this situation arising.
{"title":"The Interaction of Domestic Anti-Avoidance Rules with Tax Treaties in the Post-BEPS and Digitalized World","authors":"V. Chand, C. Elliffe","doi":"10.59403/3safqvc","DOIUrl":"https://doi.org/10.59403/3safqvc","url":null,"abstract":"In its analysis, this article distinguishes between domestic anti-avoidance rules that counteract treaty abuse and those that thwart abuse of domestic law. The authors conclude that conflicts could arise with tax treaties. States should employ a provision that authorizes the application of these rules to prevent this situation arising.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":" 23","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-03-17","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141222095","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The author, a member of the Inclusive Framework Steering Group which is engaged in discussion on the allocation of taxing rights, argues that value creation has not been and should never be the basis of such an allocation. He also urges developing countries to be careful in endorsing the concept.
{"title":"The Concept of Value Creation: Is It Relevant for the Allocation of Taxing Rights?","authors":"R.R. Das","doi":"10.59403/1g3p4gm","DOIUrl":"https://doi.org/10.59403/1g3p4gm","url":null,"abstract":"The author, a member of the Inclusive Framework Steering Group which is engaged in discussion on the allocation of taxing rights, argues that value creation has not been and should never be the basis of such an allocation. He also urges developing countries to be careful in endorsing the concept.","PeriodicalId":516699,"journal":{"name":"Bulletin for International Taxation","volume":"77 5","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-03-02","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"141225410","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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