The authors are winners of the Mitchell B. Carroll Prize for the last two consecutive years, as awarded at the International Fiscal Association global congresses in 2023 and 2024 in Cancún (Mexico)…
The author would like to give thanks to Professor Daniel Gutmann, Professor Georg Kofler, and Simon Whitehead for an engaging and intellectually stimulating exchange of views on the CJEU's judgment…
Part II. The (Toxic) Relationship of BO and GAAR in Light of the Husky Energy case.
“[T]he concept of beneficial ownership is a basic principle of income taxation: the beneficial owner of income is…
Part I. International treaty autonomous BO-GAAR relationship
“[T]he concept of beneficial ownership is a basic principle of income taxation: the beneficial owner of income is the person who should be…
“[A]ny State claiming a pioneer role in the development of new technologies bears
special responsibility for striking the right balance in this regard”
– The European Court of Human Rights in the S…
“[I]n this world, with great power comes great responsibility!”
– Uncle Ben advice to the young Peter Parker,
the 1962 Amazing Fantasy #15, by Stan Lee
1 Introduction
Explainable artificial…
1 AI and XAI in tax law [1][2]
Artificial intelligence (AI) systems are becoming increasingly central in the global economy. According to PWC estimates, they may provide boosts of up to 26…
Articles 3 and 6 ATAD: a dangerous EU legislative mix
In the forthcoming issue of Intertax, I make an in-depth analysis of the issues concerning the partial implementation of the EU GAAR, as…
Błażej Kuźniacki (ACTL, University of Amsterdam; PwC Poland)
Kamil Tyliński (Mishcon de Reya LLP; UCL School of Management)
Every new method or procedure involves not only potential benefits but also…
