In recent times mainstream media has put the spotlight on corporate tax affairs. The underlying concern is double non-taxation: that is, that some multinational

This work is the result of an extensive research into the permanent establishment concept, a concept that plays a vital role within the international taxation s

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is the most forceful multilateral initiat

Tax treaty law and EU tax law in connection with hybrid entities Hybrid entities have traditionally been used as an avenue for international tax planning, and e

Over the past few decades, the concentration of wealth and property in the hands of a few has been facilitated by tax evasion, tax avoidance, and above all by t