CFC legislations are common to most OECD Member States. They are introduced to combat tax evasion by shifting profits to corporations situated in low tax jurisdictions. Without the introduction of CFC legislations, residents are free to set up corporations abroad to lower their tax burden. The reason is the shielding effect of non-resident corporations. Thus, especially high tax countries feel the need to deny the tax benefits of Controlled Foreign Corporations in low tax countries. 70 experts, including the National and General Reporters, convened for a joint conference on CFC legislations...

Direct taxation is considered as an area within the almost exclusive competence of the individual Member States of the European Union. Some politicians believe that if the European Union intervenes in the tax systems of the Member States, the financing of the public sector of the Member States could be at risk. Even against this background, however, the European Union has exercised considerable influence in the area of direct taxation of Member States. Despite the fact that unanimity among the Member States is required to reach a Community decision in the area of direct taxation, it is now...

This unique book investigates the extent tot which a taxpayer may invoke the freedom of movement within the Community in order to avoid national direct taxes. The author shows what at the national level is viewed as abuse may often be viewed from an EC law perspective as invoking the Treaty freedoms.
Among the issues raised in the course of the analysis are the following:
- applicability of each of the freedoms of the citizen, of goods, of workers, of establishment, of services, and of capital;
- tests entailed by Community law: the economic activity test, the artificiality test,...

Sovereign states commonly use tax incentives in order to attract investment and capital from abroad. Although it has been recognized for many years that the forms and features of these incentives can often have harmful effects, there has not until now been a clear, in depth, full scale study of what these effects are, how they come about, and how they can be minimised or avoided. This new book by Carlo Pinto performs the indispensable function of crystallising the extensive European and American literature in the field, locating his legal analysis in an EU law context that offers a framework...