Deals with issues and problems raised by residence of companies for tax purposes, including detailed analysis from a national viewpoint in selected European and

The concept of residence lies at the core of corporate income taxation. In domestic tax systems, the essential function of the residence concept is to subject r

In international tax law, the term ‘beneficial ownership’ refers to which parties involved in a cross-border transaction are entitled to tax treaty benefits

"Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regard

This study considers how tax authorities attempt to strike down international tax avoidance structures, in particular those involving the use of conduit and bas