Everywhere,new tax rules are under development to engage with the ever-increasing complexity and sophistication of aggressive tax planning and to reverse the ta

Despite the conclusion of tax treaties and despite the enactment of several directives, double taxation continues to occur within the EU, causing severe obstacl

The topics of double non-taxation and hybrid entities have acquired a particular importance in a context where transformations within the tax world seem to be l

The hurdles emerging from the parallel exercise of Member States’ tax sovereignty have been examined by the CJEU and intensely discussed by scholars. By uncov

Time is a crucial dimension in the application of any law. In tax law, however, where an environment characterized by rapid change on the national, European, an