General Anti Avoidance Rules Revisited

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General Anti-Avoidance Rules Revisited

Author : David G. Duff
Publisher :
ISBN 13 :
Total Pages : 0 pages
Book Rating : 4.:/5 (137 download)

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Book Synopsis General Anti-Avoidance Rules Revisited by : David G. Duff

Download or read book General Anti-Avoidance Rules Revisited written by David G. Duff and published by . This book was released on 2020 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: In addition to the requirement of a tax benefit or advantage, the application of most modern general anti-avoidance rules turns on two elements: a so-called "subjective element" which considers the purpose for which the transaction or arrangement resulting in the tax benefit or advantage was undertaken or arranged; and an "objective element" which considers the object or purpose of the relevant provisions to determine if the tax benefit resulting from the transaction or arrangement is or is not consistent with this object or purpose.Although these two elements are present in most modern GAARs, the function of each element within these rules and the relationship between them is often poorly understood. Other unresolved issues concern the roles of artificiality and economic substance in the application of these rules, and the relationship, if any, between these concepts and the "subjective" and "objectives" elements of the rules. A final set of issues involves the uncertainty that GAARs may engender, the ability of judges to apply these rules and principles in a coherent and consistent manner, and the compatibility of these rules and principles with the rule of law.This essay addresses these issues by reflecting on Tim Edgar's article “Building a Better GAAR”. Part 1I considers the rationale for a general anti-avoidance rule or principle, arguing that it not only represents a useful policy response to the harmful consequences of tax avoidance (the consequentialist argument that Professor Edgar espoused), but that it may also be justified on the non-consequentialist grounds that it protects the integrity of the provisions at issue and thereby upholds the rule of law. Part III builds on this analysis to consider the design of a general anti-avoidance rule or principle, arguing that it should be codified in the form of an explicit rule, should include subjective and objective elements like the purpose and misuse or abuse requirements in the Canadian GAAR, and should be informed by concepts of artificiality and economic substance which apply respectively to the subjective and objective elements of the rule. Part IV concludes.

General Anti-Avoidance Rules Revisited : Reflections on Tim Edgar's "Building a Better GAAR".

Download General Anti-Avoidance Rules Revisited : Reflections on Tim Edgar's

Author : D.G. Duff
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (126 download)

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Book Synopsis General Anti-Avoidance Rules Revisited : Reflections on Tim Edgar's "Building a Better GAAR". by : D.G. Duff

Download or read book General Anti-Avoidance Rules Revisited : Reflections on Tim Edgar's "Building a Better GAAR". written by D.G. Duff and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In addition to the requirement of a tax benefit or advantage, the application of most modern general anti-avoidance rules (GAARs) turns on two elements: a "subjective element", which considers the purpose for which the transaction or arrangement resulting in the tax benefit or advantage was undertaken or arranged; and an "objective element", which considers the object or purpose of the relevant provisions to determine whether the tax benefit resulting from the transaction or arrangement is consistent with this object or purpose. Although these two elements are present in most modern GAARs, the function of each element within these rules and the relationship between them are often poorly understood. Other unresolved issues concern the roles of artificiality and economic substance in the application of these rules, and the relationship, if any, between these concepts and the "subjective" and "objective" elements of the rules. A final set of issues involves the uncertainty that GAARs may engender, the ability of judges to apply these rules and principles in a coherent and consistent manner, and the compatibility of these rules and principles with the rule of law. The author addresses these issues by reflecting on Tim Edgar's article "Building a Better GAAR". The first part of the paper considers the rationale for a general antiavoidance rule or principle, arguing that such a rule not only represents a useful policy response to the harmful consequences of tax avoidance (the consequentialist argument that Professor Edgar espoused), but also may be justified on the non-consequentialist grounds that it protects the integrity of the provisions at issue and thereby upholds the rule of law. In the second part of the paper, the author builds on this analysis to consider the design of a general anti-avoidance rule or principle, arguing that it should be codified in the form of an explicit rule, should include subjective and objective elements such as the "purpose" and "misuse or abuse" requirements in the Canadian GAAR, and should be informed by concepts of artificiality and economic substance that apply to, respectively, the subjective and objective elements of the rule.

A Multilateral Convention for Tax

Author : Sergio André Rocha
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041194290
Total Pages : 401 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis A Multilateral Convention for Tax by : Sergio André Rocha

Download or read book A Multilateral Convention for Tax written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2021-11-29 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is the most forceful multilateral initiative to coordinate tax regimes on a worldwide basis since the dawn of modern income taxation over a century ago. This book evaluates two radically opposed viewpoints on the convention—a momentous and revolutionary paradigm shift versus a mechanism that merely continues an ongoing flow of limited policy coordination—with detailed investigations that bring to life the hopes and the realities of the current era of multilateral tax cooperation. Bringing together authors from national jurisdictions across the globe to scrutinize the MLI and its likely future ramifications, the book provides in-depth commentary and analysis in the following sequence: first, a comprehensive discussion of the design and goals of the MLI as a treaty and an institutional framework; second, an overview of the structure of the convention and its take-up across the globe to date; and third, the substantive implementation of the MLI with a wide range of country reports. Practice areas covered include tax law, international law, and international relations. The legal workings and implications of the MLI might still seem mysterious to those whose daily work is impacted by it, and there is as yet little jurisprudence regarding its legal nature or ultimate effect on the bilateral treaties coming within its scope. For these reasons, this pathbreaking book will be warmly welcomed by in-house counsel and law firms advising cross-border investors and firms; nongovernmental organizations involved in policy analysis and issue advocacy; researchers working on technical areas of international tax law; and lawyers interested in international policymaking, including the creation and diffusion of consensus-based fiscal and related regulatory norms across jurisdictions of differing development levels.

GAARs and Judicial Anti-Avoidance in Germany, the UK and the EU

Author : Markus Seiler
Publisher : Linde Verlag GmbH
ISBN 13 : 3709408164
Total Pages : 336 pages
Book Rating : 4.7/5 (94 download)

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Book Synopsis GAARs and Judicial Anti-Avoidance in Germany, the UK and the EU by : Markus Seiler

Download or read book GAARs and Judicial Anti-Avoidance in Germany, the UK and the EU written by Markus Seiler and published by Linde Verlag GmbH. This book was released on 2016-06-28 with total page 336 pages. Available in PDF, EPUB and Kindle. Book excerpt: GAARS: the better insight into a country’s tax system In a post-BEPS tax world and in times of an ever-increasing need for tax revenue, policy-makers are more willing than ever to tighten or adopt General Anti-Avoidance Rules (GAARs). A GAAR is typically a broad principle-based rule trying to establish the borderline between “abuse” and “use” of a law, thereby addressing the phenomenon that as long as there have been taxes, persons have been trying to reduce their tax bills. This award-winning book compares the GAARs and judicial anti-avoidance approaches of Germany, the UK and the EU. It gives a deep insight into the predominant legal traditions of the Western World, comprehensively analyses case-law and offers unique perspectives on tax law across jurisdictions. This book reveals that there is no other feature of tax law that provides a better insight into a country’s tax system than its anti-avoidance rules. GAARs and their historical background reveal so much about judicial perspectives on taxation and legal interpretation, citizens’ tax morale, drafters’ inclinations for technical or principled drafting or legislators’ willingness to confront politically sensitive issues. Understanding the role of GAARs ultimately also reveals whether they are a suitable means to counteract tax avoidance effectively. The Book is the winner of the Wolfgang Gassner-Wissenschaftspreis 2016!

The Routledge Companion to Tax Avoidance Research

Author : Nigar Hashimzade
Publisher : Routledge
ISBN 13 : 1317377087
Total Pages : 476 pages
Book Rating : 4.3/5 (173 download)

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Book Synopsis The Routledge Companion to Tax Avoidance Research by : Nigar Hashimzade

Download or read book The Routledge Companion to Tax Avoidance Research written by Nigar Hashimzade and published by Routledge. This book was released on 2017-10-02 with total page 476 pages. Available in PDF, EPUB and Kindle. Book excerpt: An inherently interdisciplinary subject, tax avoidance has attracted growing interest of scholars in many fields. No longer limited to law and accounting, research increasingly has been conducted from other perspectives, such as anthropology, business ethics, corporate social responsibility, and economic psychology. This was –recently stimulated by politicians, mass media, and the public focussing on tax avoidance after the global financial and economic crisis put a squeeze on private and public finances. New challenges were posed by changing definitions and controversies in the interpretation of tax avoidance concept, as well as a host of new rules and policies that need to be fully understood. This collection provides a comprehensive guide to students and academics on the subjects of tax avoidance from an interdisciplinary perspective, exploring the areas of accounting, law, economics, psychology, and sociology. It covers global as well as regional issues, presents a discussion of the definition, legality, morality, and psychology of tax avoidance, and provides guidance on measurement of economic effect of tax avoidance activities. With a truly international selection of authors from the UK, North America, Africa, Asia, Australasia, Middle East, and continental Europe, with well-known experts and rising stars of the field, the contributors cover the entire terrain of this important topic. The Routledge Companion to Tax Avoidance Research is a ground-breaking attempt to bring together scholarly research in tax avoidance, offering rigorous academic analysis of an important and hotly debated issue in a structured and balanced way.

Tax Avoidance and the Law

Author : Selina Keesoony
Publisher : Taylor & Francis
ISBN 13 : 1000598446
Total Pages : 210 pages
Book Rating : 4.0/5 (5 download)

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Book Synopsis Tax Avoidance and the Law by : Selina Keesoony

Download or read book Tax Avoidance and the Law written by Selina Keesoony and published by Taylor & Francis. This book was released on 2022-05-30 with total page 210 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax Avoidance and the Law is a helpful guide for undergraduate and postgraduate students who want a thorough understanding of this dynamic area of law. The book is written in a way which is easy to follow and conveniently summarises complex case law on tax avoidance. Tax Avoidance and the Law explores the evolution of the UK’s General Anti- Abuse Rule. It provides a useful comparison with other Western jurisdictions’ anti-avoidance legislation, including the United States of America, Australia, New Zealand, South Africa, Canada and the EU. The underlying theme of the book rests on the notion that the taxpayer’s subjective motives, intentions or purposes are irrelevant when assessing tax liability. The book enables students to gain a good grasp of the fundamental issues in tax avoidance in a clear manner.

Legislating Against Tax Avoidance

Author : Rachel Anne Tooma
Publisher : IBFD
ISBN 13 : 9087220340
Total Pages : 405 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis Legislating Against Tax Avoidance by : Rachel Anne Tooma

Download or read book Legislating Against Tax Avoidance written by Rachel Anne Tooma and published by IBFD. This book was released on 2008 with total page 405 pages. Available in PDF, EPUB and Kindle. Book excerpt: Proposes a uniform statutory GAAR for the Federation of Australia, and examines "the experiences of countries with (e.g., Australia, Canada, New Zealand and South Africa) and without (e.g., the United States of America and the United Kingdom) a statutory GAAR"--Page ix.

Beneficial Ownership in International Taxation

Author : Kuźniacki, Błażej
Publisher : Edward Elgar Publishing
ISBN 13 : 1802206078
Total Pages : 385 pages
Book Rating : 4.8/5 (22 download)

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Book Synopsis Beneficial Ownership in International Taxation by : Kuźniacki, Błażej

Download or read book Beneficial Ownership in International Taxation written by Kuźniacki, Błażej and published by Edward Elgar Publishing. This book was released on 2022-08-12 with total page 385 pages. Available in PDF, EPUB and Kindle. Book excerpt: This authoritative book provides a structural, global view of evolving judicial and doctrinal trends in the understanding of beneficial ownership in international taxation. Błażej Kuźniacki presents a route towards an international autonomous meaning of beneficial ownership, while also offering a comprehensive explanation of the divergent understandings and tax policy arguments underpinning its continuing ambiguity.

Studies in the History of Tax Law, Volume 8

Author : Peter Harris
Publisher : Bloomsbury Publishing
ISBN 13 : 1509908382
Total Pages : 549 pages
Book Rating : 4.5/5 (99 download)

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Book Synopsis Studies in the History of Tax Law, Volume 8 by : Peter Harris

Download or read book Studies in the History of Tax Law, Volume 8 written by Peter Harris and published by Bloomsbury Publishing. This book was released on 2017-08-10 with total page 549 pages. Available in PDF, EPUB and Kindle. Book excerpt: These are the papers from the 8th Cambridge Tax Law History Conference held in July 2016. In the usual manner, these papers have been selected from an oversupply of proposals for their interest and relevance, and scrutinised and edited to the highest standard for inclusion in this prestigious series. The papers fall within five basic themes: Two papers focus on tax theory; one on John Locke and another on the impact of English tax literature in the Netherlands in the nineteenth century. Five deal with the history of UK specific interpretational issues in varying contexts – an ancient exemption, insurance companies, special contribution, the profits tax GAAR and capital gains tax. Two more papers consider aspects of HMRC operations. Another three focus on facets of international taxation, including treaties between the UK and European countries, treaties between the UK and developing countries and the UN model tax treaties of 1928. The book also incorporates a range of interesting topics from other countries, including the introduction of income tax in Ireland and in Chile, post-war income taxation in Australia, early interpretation of 'income' in New Zealand and a discussion of some early indirect taxes in India and China.

Taxation of Derivatives and Cryptoassets

Author : Oktavia Weidmann
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403524057
Total Pages : 519 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Taxation of Derivatives and Cryptoassets by : Oktavia Weidmann

Download or read book Taxation of Derivatives and Cryptoassets written by Oktavia Weidmann and published by Kluwer Law International B.V.. This book was released on 2024-06-10 with total page 519 pages. Available in PDF, EPUB and Kindle. Book excerpt: Derivatives stand at the forefront of financial innovation, continually evolving to accommodate new asset classes and risk categories. In the past decade, the growing popularity of cryptoassets and ESG investments has sparked the development of a variety of innovative investment strategies and risk management tools, including crypto and ESG derivatives and related structured products. This new edition has similarly evolved. Using illustrative examples, it provides a comprehensive analysis of the key tax issues associated with derivatives and cryptoassets in domestic and cross-border transactions and presents approaches that tax legislators could adopt to solve them. The new edition also comments on recent trends in global tax policy, such as the OECD Base Erosion and Profit Shifting (BEPS) 1.0 and 2.0 projects. Throughout the book, specific references are made to UK, German, and Swiss tax law. The updated edition addresses the following topics: economic and financial properties of derivatives and cryptoassets; definition of derivatives for tax purposes and its application to crypto derivatives and ESG derivatives, among others; accounting treatment of derivatives and cryptoassets under IFRS, UK, German and US GAAP; current tax legislation and policy alternatives to the taxation of derivatives and cryptoassets; characterisation of derivatives gains and losses as income or capital, and equity or debt; accounting and taxation treatment of hedging transactions involving derivatives or cryptoassets; accounting and taxation rules applying to structured products and hybrid instruments, including crypto and ESG-linked structured products; withholding taxes on derivatives and the concept of beneficial ownership in domestic and cross-border transactions; and anti-avoidance legislation applying to derivatives and cryptoassets, including the domestic law implementation of BEPS Action 2, the EU Anti-Tax Avoidance Directives (ATAD I and II), the tax transparency rules for cryptoassets (DAC8) and Pillar Two. This comprehensive book analyses recent developments in three intertwined areas of expertise: financial products, accounting and tax law. It will be a valuable resource to tax professionals in their daily practice of advising companies, banks and investment funds. It will also be of interest to government officials and researchers engaged in the taxation of derivatives, cryptoassets, and ESG investment products.

Human Rights and Taxation in Europe and the World

Author : Georg Kofler
Publisher : IBFD
ISBN 13 : 9087221118
Total Pages : 581 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis Human Rights and Taxation in Europe and the World by : Georg Kofler

Download or read book Human Rights and Taxation in Europe and the World written by Georg Kofler and published by IBFD. This book was released on 2011 with total page 581 pages. Available in PDF, EPUB and Kindle. Book excerpt: Resumen del editor: "The increasing globalization and the restructuring of the European legal framework by the Treaty of Lisbon are important factors to suggest that the traditional separation of spheres between taxation and human rights should be revisited. This book examines the issues surrounding the impact of the Lisbon Treaty on the guarantee and enforcement of human rights in the area of EU (tax) law and explores the possible development and potential impact of human rights in the field of taxation in this age of global law."

Index to Canadian Legal Periodical Literature

Author :
Publisher :
ISBN 13 :
Total Pages : 236 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Index to Canadian Legal Periodical Literature by :

Download or read book Index to Canadian Legal Periodical Literature written by and published by . This book was released on 2004 with total page 236 pages. Available in PDF, EPUB and Kindle. Book excerpt:

The Dynamics of Taxation

Author : Glen Loutzenhiser
Publisher : Bloomsbury Publishing
ISBN 13 : 1509929118
Total Pages : 574 pages
Book Rating : 4.5/5 (99 download)

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Book Synopsis The Dynamics of Taxation by : Glen Loutzenhiser

Download or read book The Dynamics of Taxation written by Glen Loutzenhiser and published by Bloomsbury Publishing. This book was released on 2020-10-15 with total page 574 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book brings together a landmark collection of essays on tax law and policy to celebrate the legacy of Professor Judith Freedman. It focuses on the four areas of taxation scholarship to which she made her most notable contributions: taxation of SMEs and individuals, tax avoidance, tax administration, and taxpayers' rights and procedures. Professor Freedman has been a major driving force behind the development of tax law and policy scholarship, not only in the UK, but worldwide. The strength and diversity of the contributors to this book highlight the breadth of Professor Freedman's impact within tax scholarship. The list encompasses some of the most renowned taxation experts worldwide; they include lawyers, economists, academics and practitioners, from Britain, Canada, Portugal, Australia, Germany, Italy, Malta, Ireland, and Ukraine.

GAARs - a Key Element of Tax Systems in the Post-BEPS Tax World

Author : Michael Lang
Publisher :
ISBN 13 : 9789087223588
Total Pages : 840 pages
Book Rating : 4.2/5 (235 download)

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Book Synopsis GAARs - a Key Element of Tax Systems in the Post-BEPS Tax World by : Michael Lang

Download or read book GAARs - a Key Element of Tax Systems in the Post-BEPS Tax World written by Michael Lang and published by . This book was released on 2016 with total page 840 pages. Available in PDF, EPUB and Kindle. Book excerpt: General anti-avoidance rules (GAARs) have been a topic of great relevance in practice as well as in academia for decades. In a post-BEPS tax world, with national legislators introducing or tightening GAARs, and with the European Union and OECD suggesting implementation of such rules, the topic seems more important than ever. The aim of this book is to give tax policymakers, tax authorities, tax courts and tax practitioners an idea of the various understandings of and approaches towards tax avoidance in 39 countries.

Tax Authority Advice and the Public

Author : Stephen Daly
Publisher : Bloomsbury Publishing
ISBN 13 : 1509930558
Total Pages : 265 pages
Book Rating : 4.5/5 (99 download)

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Book Synopsis Tax Authority Advice and the Public by : Stephen Daly

Download or read book Tax Authority Advice and the Public written by Stephen Daly and published by Bloomsbury Publishing. This book was released on 2020-04-02 with total page 265 pages. Available in PDF, EPUB and Kindle. Book excerpt: There is now almost universal acceptance that tax law is overly complex and indeterminate; and yet, there has to date been no comprehensive assessment of the role of the tax authority in the current arrangement. If the legislation and case law offer few immediate answers to the taxpayer, then the role of Her Majesty's Revenue & Customs (HMRC) in advising taxpayers becomes more apparent. This monograph contends that the provision of advice by HMRC is desirable by virtue of the rule of law and it follows that any such advice should be correct, clear, accessible and reliable. Additionally, there should exist some means of scrutinising the advice in order to check that it satisfies these criteria. Tax Authority Advice and the Public explores this view of HMRC's role in tax collection. It explains the deficiencies in the current system in this light, highlighting the pitfalls for taxpayers and practitioners as well as the potential remedies. Finally, the book assesses potential reforms which could be adopted in order to alleviate existing problems. A timely and ambitious work, this book is essential reading for practitioners and academics interested in the interaction between tax administration and public law.

Concept and Implementation of CFC Legislation

Author : Nathalie Bravo
Publisher : Linde Verlag GmbH
ISBN 13 : 3709411580
Total Pages : 536 pages
Book Rating : 4.7/5 (94 download)

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Book Synopsis Concept and Implementation of CFC Legislation by : Nathalie Bravo

Download or read book Concept and Implementation of CFC Legislation written by Nathalie Bravo and published by Linde Verlag GmbH. This book was released on 2021-09-21 with total page 536 pages. Available in PDF, EPUB and Kindle. Book excerpt: An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law. Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.

Hybrid Financial Instruments, Double Non-Taxation and Linking Rules

Author : Félix Daniel Martínez Laguna
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403510846
Total Pages : 668 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Hybrid Financial Instruments, Double Non-Taxation and Linking Rules by : Félix Daniel Martínez Laguna

Download or read book Hybrid Financial Instruments, Double Non-Taxation and Linking Rules written by Félix Daniel Martínez Laguna and published by Kluwer Law International B.V.. This book was released on 2019-06-12 with total page 668 pages. Available in PDF, EPUB and Kindle. Book excerpt: Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.