engleski

Literature Review: Corporate Tax Residency and Mobility, Edoardo Traversa (editor), EATLP International Tax Series, IBFD, 2018

News on the imminent demise of time-honoured pillars of “international tax regime” in the aftermath of the Base Erosion and Profit Shifting (BEPS) project seem to be, as in Mark Twain’s case, grossly exaggerated. Even without the luxury of hindsight, this does not come as a surprise, since the project itself has ever from its inception resonated more the anti-tax avoidance sentiment of the general public, rather than having been aimed at a complete overhaul of the international tax rules. Put in the by now well-known BEPS jargon, the emphasis was on the “coherence” instead of on the “substance”. Accordingly, the interested reader often encounters scholarly publications aimed at providing a fresh look at seemingly all-too- familiar notions and concepts. The book before us falls in this category, providing an exhaustive analysis of the concept of (corporate) tax residence, which constitutes a cornerstone of contemporary income tax systems.

tax residence ; international tax law ; BEPS.

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