Corporate taxation has become an important topic of public debate and corporate tax planning has met with strong societal criticism. In response to these societal concerns, the Organization for... Show moreCorporate taxation has become an important topic of public debate and corporate tax planning has met with strong societal criticism. In response to these societal concerns, the Organization for Economic Co-operation and Development (OECD) launched the OECD/G20 BEPS project. In light of these developments, research on the professional practice of corporate tax planning has become more relevant. In this book, the author investigates tax professionals’ reactions to changing societal expectations of corporate tax planning. Taking a qualitative approach, the responses of different types of tax professionals of the Dutch corporate tax field were examined. Particular attention was paid to the manner in which tax professionals understand corporate tax planning and the public discussion, to what degree societal norms influence the professional practice of corporate taxation, and to what degree tax professionals have altered their role perceptions in response to public concerns of corporate tax planning. Show less
The effect of directives within the area of direct taxation on tax treaties has become more and more relevant in light of the increasing overlap between situations covered by directives and tax... Show moreThe effect of directives within the area of direct taxation on tax treaties has become more and more relevant in light of the increasing overlap between situations covered by directives and tax treaties, the changing nature of obligations arising from directives, and the interpretation by the EU Court of Justice of terms in directives that are similar to terms used in tax treaties. This book contains an analysis of the effect of directives on the interpretation and application of tax treaties from the perspectives of public international law and the laws of the EU. Regarding the effect of directives on the interpretation of tax treaties, this book addresses the question whether directives qualify must be taken into account when resorting to article 3(2) OECD Model and article 31 Vienna Convention 1969 and, if so, to what extent they could affect the interpretation of a tax treaty (while taking into account the duty of conforming interpretation). Additionally, this book looks into to what extent directives could affect the application of tax treaties under the conflict rules of public international law (lex posterior, lex specialis) as well as by means of the primacy of directives under the laws of the EU Show less
The dissertation studies harmful tax competition in the East African Community (EAC). With a focus on Rwanda, it mainly refers to the EU and OECD standards. The objective of the study was to... Show moreThe dissertation studies harmful tax competition in the East African Community (EAC). With a focus on Rwanda, it mainly refers to the EU and OECD standards. The objective of the study was to investigate Rwanda’s tax competition practices, in order to determine whether Rwanda is within the parameters of internationally accepted practices. The main orientation was not to draw a new distinction between acceptable versus unacceptable tax practices. Rather, it was to apply the criteria already developed and accepted at the international level to the particular case of Rwanda. The main materials used are: the EAC Treaty, the draft EAC Code of Conduct against harmful tax competition, the 1997 EU Code of Conduct on business taxation, the 1998 OECD Report on harmful tax competition, the COCG assessment reports, the OECD Progress reports, the Rwandan income tax law of 2018 and the investment law of 2021. This dissertation shows the possibility of applying EU and OECD standards by non- OECD and EU countries, particularly developing countries, to create tax systems that are free of harmful tax competition. However, it also shows that OECD and EU standards are not sufficient to eradicate all harmful tax practices, both in developed and developing countries. Show less
The rationale behind this study is to describe four problems of death and gift taxes in a cross-border setting and to provide solutions to these problems under the current international and EU law... Show moreThe rationale behind this study is to describe four problems of death and gift taxes in a cross-border setting and to provide solutions to these problems under the current international and EU law mechanisms. These problems are double or multiple taxation, double or multiple non-taxation, discrimination and administrative difficulties. The selection of these problems is justified by the two main points of reference selected in the study, the 1982 OECD Model Tax Convention for the avoidance of double taxation with respect to taxes on inheritances, estates and gifts (OECD IHTMTC), and the inheritance tax report of the European Commission’s expert group, ‘Ways to tackle inheritance cross-border tax obstacles facing individuals within the EU’ from 2015. The study serves as up-to-date material for tax professionals, policymakers, academics and students as well as the general public who want to understand, amongst others, the problems of death and gift taxation in a cross-border setting, how the international and EU law mechanisms in this area of law work in practice, how the OECD IHTMTC can be improved, how the CJ’s case law on EU inheritance and gift taxation has resulted in the so-called ‘negative harmonisation’ of death and gift taxes in the EU, and whether the ‘one inheritance – one inheritance tax’ concept suggested in the inheritance tax report can provide a holistic solution to the problems of death and gift taxation in the EU. Show less
Over the last decades, income inequality has increased globally. How do social policies affect this increasing trend? How do international trade and technological progress affect inequality? What... Show moreOver the last decades, income inequality has increased globally. How do social policies affect this increasing trend? How do international trade and technological progress affect inequality? What is the profile of income inequality in China? Based on quantitative analyses of determinants of income inequality, this study provides a number of new insights into these questions. Income inequality has increased in the last decades all over the world. Several factors seem to contribute to this trend. Very prominent amongst them is the rising primary income inequality. The dominant income inequality-reducing effect comes from the tax benefit system, which offsets two thirds of the total increase in inequality. Generally speaking, the transition of welfare states from a traditional to a social investment oriented system does not lead to lower income inequality or poverty. There is also no robust and significant relationship between international trade and technology changes on the one hand, and income inequality on the other. Determinants of inequality in China are different from those in developed countries. In contrast to the tax benefit system in rich countries, the fiscal system in China does not bring a lower level of income inequality. Another explanation is the household registration system. Show less
