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The Role of the Subjective Element in Tax Abuse and Aggressive Tax Planning
15 references·1 citing·32 second hop
The Role of the Subjective Element in Tax Abuse and Aggressive Tax Planning (2018)The Role of the Subjective Element in Tax…Tax Abuse and Aggressive Tax Planning in the BEPS Era: How EU Law and the OECD Are Establishing a Unifying Conceptual Framework in International Tax Law, despite Linguistic Discrepancies (2017)Tax Abuse and Aggressive Tax …GAARs and Treaties: From the Guiding Principle to the Principal Purpose Test. What Have We Gained from BEPS Action 6? (2017)GAARs and Treaties: From the …The Impact of the ATAD on Domestic Systems: A Comparative Survey (2016)The Impact of the ATAD on Dom…The Concept of Aggressive Tax Planning Launched by the OECD and the EU Commission in the BEPS Era: Redefining the Border between Legitimate and Illegitimate Tax Planning (2016)The Concept of Aggressive Tax…Anti-Tax Avoidance Directive (2016/1164): New EU Policy Horizons (2016)Anti-Tax Avoidance Directive …The General Anti-Abuse Rule of the Parent-Subsidiary Directive (2015)The General Anti-Abuse Rule o…OECD Base Erosion and Profit Shifting Action 6: The General Anti-Abuse Rule (2015)OECD Base Erosion and Profit …Aggressive Tax Planning in EU Law and in the Light of BEPS: The EC Recommendation on Aggressive Tax Planning and BEPS Actions 2 and 6 (2015)Aggressive Tax Planning in EU…International Tax Justice between Machiavelli and Habermas (2014)International Tax Justice bet…BEPS Action 6: Introducing an Antiabuse Rule in Tax Treaties (2014)BEPS Action 6: Introducing an…Towards a Homogeneous Theory of Abuse in EU (Direct) Tax Law (2012)Towards a Homogeneous Theory …Shared subjective views, intent to cooperate and tax compliance: Similarities between Australian taxpayers and tax officers (2006)Shared subjective views, inte…The Theory of Tax Evasion: A Retrospective View (2005)The Theory of Tax Evasion: A …Line Drawing, Doctrine, and Efficiency in the Tax Law (1998)Line Drawing, Doctrine, and E…The Elusive Spirit of the Law: Formalism and the Struggle for Legal Control (1991)The Elusive Spirit of the Law…Danish Cases on the Use of Holding Companies for Cross-Border Dividends and Interest – A New Test to Disentangle Abuse from Real Economic Activity? (2020)Danish Cases on the Use of Ho…Crime and Punishment: An Economic Approach (1968)Income tax evasion: a theoretical analysis (1972)An Inquiry into the Nature and Causes of the Wealth of Nations (1977)Measuring, explaining, and controlling tax evasion: lessons from theory, experiments, and field studies (2011)TESTING ENFORCEMENT STRATEGIES IN THE FIELD: THREAT, MORAL APPEAL AND SOCIAL INFORMATION (2013)Extrinsic and Intrinsic Motivations for Tax Compliance: Evidence from a Field Experiment in Germany (2016)What Do Judges and Justices Maximize? (The Same Thing Everybody Else Does) (1993)Social Norms and Social Roles (1996)A Behavioral Approach to Law and Economics (2000)Agency Models in Law and Economics (2000)Cost-Benefit Analysis and Relative Position (2000)Group Judgments: Deliberation, Statistical Means, and Information Markets (2004)Influence : science and practice (1985)Rediscovering the Social Group: A Self‐Categorization Theory (1987)Rediscovering the Social Group: A Self-Categorization Theory. (1989)Tax compliance of small business owners (2012)A conceptual framework of tax knowledge (2019)How to Achieve Tax Compliance by the Wealthy: A Review of the Literature and Agenda for Policy (2019)Tax and Corporate Governance (2008)The 21st Century Multilateralism in International Taxation: The Emperor’s New Clothes? (2016)What Is Really Wrong with Global Tax Governance and How to Properly Fix It (2018)Perspectives on Corporate Social Responsibility (2008)Compliance Theory: A Goal Framing Approach (2011)When Compliance is not the Solution but the Problem: From Changes in Law to Changes in Attitude (2017)Abuse and Aggressive Tax Planning: Between OECD and EU Initiatives – The Dividing Line between Intended and Unintended Double Non-Taxation (2017)The Single Tax Principle: Fiction or Reality in a Non-Comprehensive International Tax Regime? (2019)European Union Corporate Tax Law (2013)Final Report on Action 6 of the OECD/G20 Base Erosion and Profit Shifting Initiative: Prevention of Treaty Abuse (2016)The Signalling Function of Article 29(9) of the OECD Model – The “Principal Purpose Test” (2020)Chapter 2: Tax Avoidance and Aggressive Tax Planning as an International Standard – BEPS and the “New” Standards of (Legal and Illegal) Tax Avoidance (2017)Fiscal State Aid Law and Harmful Tax Competition in the European Union (2023)At a Crossroads: Mandatory Disclosure under DAC-6 and EU Primary Law – Part 2 (2019)
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References

  • 2005The Theory of Tax Evasion: A Retrospective View620 cited
  • 1991The Elusive Spirit of the Law: Formalism and the Struggle for Legal Control282 cited
  • 1998Line Drawing, Doctrine, and Efficiency in the Tax Law199 cited
  • 2006Shared subjective views, intent to cooperate and tax compliance: Similarities between Australian taxpayers and tax officers144 cited
  • 2015Aggressive Tax Planning in EU Law and in the Light of BEPS: The EC Recommendation on Aggressive Tax Planning and BEPS Actions 2 and 658 cited
  • 2014BEPS Action 6: Introducing an Antiabuse Rule in Tax Treaties50 cited
  • 2012Towards a Homogeneous Theory of Abuse in EU (Direct) Tax Law36 cited
  • 2017GAARs and Treaties: From the Guiding Principle to the Principal Purpose Test. What Have We Gained from BEPS Action 6?36 cited
  • 2016The Concept of Aggressive Tax Planning Launched by the OECD and the EU Commission in the BEPS Era: Redefining the Border between Legitimate and Illegitimate Tax Planning35 cited
  • 2014International Tax Justice between Machiavelli and Habermas33 cited
  • 2016Anti-Tax Avoidance Directive (2016/1164): New EU Policy Horizons32 cited
  • 2015The General Anti-Abuse Rule of the Parent-Subsidiary Directive30 cited
  • 2015OECD Base Erosion and Profit Shifting Action 6: The General Anti-Abuse Rule30 cited
  • 2017Tax Abuse and Aggressive Tax Planning in the BEPS Era: How EU Law and the OECD Are Establishing a Unifying Conceptual Framework in International Tax Law, despite Linguistic Discrepancies

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28 cited
  • 2016The Impact of the ATAD on Domestic Systems: A Comparative Survey21 cited
  • Cited by

    • 2020Danish Cases on the Use of Holding Companies for Cross-Border Dividends and Interest – A New Test to Disentangle Abuse from Real Economic Activity?16 cited