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World Tax Journal
Article . 2024 . Peer-reviewed
Data sources: Crossref
World Tax Journal
Article . 2024
Data sources: WU Research
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Public International Law and Tax Law: A Fair and Equitable Nexus in International Taxation

A Fair and Equitable Nexus in International Taxation
Authors: Pistone, Pasquale; Van der Vlugt, Sam; Serafimova, Mariya;

Public International Law and Tax Law: A Fair and Equitable Nexus in International Taxation

Abstract

This article, inspired by the authors’ participation in the research of the Tax Committee of the International Law Association, calls into question the appropriateness of the traditional definition of “tax nexus” and stresses the need to reconcile the existing rules with the principles of international law. It outlines possible avenues for establishing workable, fair and common criteria and rules for the definition of “tax nexus” that operate globally. The article focuses on the existing rules on international tax nexus, inter alia, residence and source, taking into account the principles of public international law, such as those related to tax sovereignty. It proposes the development of a new fair and equitable tax nexus to address the challenges of the globalized modern world, which can potentially draw from the practice in other areas of law, such as competition law. In such a global context, the goal is to verify whether and in which cases multiple criteria for nexus can be replaced with a single nexus based on the concept of the closest connection to a single jurisdiction.

Countries
Netherlands, Austria
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Keywords

SAI 2007-05 FA

  • BIP!
    Impact byBIP!
    selected citations
    These citations are derived from selected sources.
    This is an alternative to the "Influence" indicator, which also reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
    5
    popularity
    This indicator reflects the "current" impact/attention (the "hype") of an article in the research community at large, based on the underlying citation network.
    Top 10%
    influence
    This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
    Top 10%
    impulse
    This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network.
    Top 10%
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selected citations
These citations are derived from selected sources.
This is an alternative to the "Influence" indicator, which also reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Citations provided by BIP!
popularity
This indicator reflects the "current" impact/attention (the "hype") of an article in the research community at large, based on the underlying citation network.
BIP!Popularity provided by BIP!
influence
This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Influence provided by BIP!
impulse
This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network.
BIP!Impulse provided by BIP!
5
Top 10%
Top 10%
Top 10%
hybrid
Fields of Science
Fields of Science
Related to Research communities