A Journey Through European and International Taxation

Editors
Contributors

Preface

PART I
History of Taxation

CHAPTER 1
Writing Tax History
Wolfgang Schön
CHAPTER 2
Twenty-Five Years of EATLP
Bertil Wiman
CHAPTER 3
Taxing Wartime Profits: Belgian Measures at the End of World War II
Niels Bammens
CHAPTER 4
Lessons from the Negotiations of the Franco-Dutch Convention Signed in 1949
Marilyne Sadowsky

PART II
Politics of Taxation

CHAPTER 5
Value Imperialism and Global Tax Policy: A Plea for a Meta Regime
Peter Hongler
CHAPTER 6
(Re)considering the Legitimacy of International Tax Standards: A Proposal for (Re)formulation
F. Alfredo García Prats
CHAPTER 7
Citizens’ Initiatives in Tax Matters: A Glimpse of EU Law and French Constitutional Law
Daniel Gutmann
CHAPTER 8
Ten Years into the BEPS Project: A Snapshot of Legitimacy and Justice in International Tax Lawmaking
Rita Szudoczky
CHAPTER 9
The Desired and the Actual Role of Public Consultations in Tax Lawmaking in Poland
Wlodzimierz Nykiel, Ziemowit Kukulski & Malgorzata Sek

PART III
General Notions of Taxation

CHAPTER 10
Cameleon Taxation
Daniel Deak
CHAPTER 11
Developing Sustainable Corporate Tax Governance
Hans Gribnau
CHAPTER 12
Recognition of Inflation in Income Tax Law
Roman Seer
CHAPTER 13
The Notion of Income from Capital: Twenty Years Later
Johanna Hey
CHAPTER 14
The Ability-to-Pay Principle in Hungarian Context
István Simon
CHAPTER 15
The Taxation of Pension in Italy
Eugenio Ruggiero

PART IV
European Tax Law

CHAPTER 16
The EU (Direct) Tax Policy: Reflections on Current Trends
Adolfo Martín Jiménez
CHAPTER 17
Should We Veto the Proposed Abolition of the Unanimity Rule in EU Taxation?
Cees Peters
CHAPTER 18
More EU Law and Less Prozac: Revisiting Pescatore’s The Law of Integration in 2023
Ricardo García Antón
CHAPTER 19
A Wishful Thinking Towards a European Tax Agency
Giuseppe Marino
CHAPTER 20
Tax Cooperation Between the European Union and China
Diheng Xu
CHAPTER 21
Ne bis in Idem: Article 4 of Protocol No. 7 to the European Convention on Human Rights
Philip Baker
CHAPTER 22
Tax Whistleblowing in a Digitalized Taxation Model: The Need for Legal Protection of the Whistleblowing Tax Official
Bruno Peeters & Sylvie De Raedt
CHAPTER 23
Sliding Scales of Review in State Aid Control of Fiscal Aid Measures
Joachim Englisch
CHAPTER 24
From the Proposed EU Transfer Pricing Arbitration Directive to the Proposed EU Transfer Pricing Directive: A Guided Path Through Half a Century of History of Tax Law in the European Union
Pasquale Pistone
CHAPTER 25
The Impact of CJEU Decisions in Preliminary Ruling Proceedings on German Tax Law with Particular Focus on Procedural Law
Steffen Lampert
CHAPTER 26
Controversy Regarding the Subject-to-Tax Requirement in the EU Parent-Subsidiary Directive (2011/96) and in the Polish Corporate Income Tax Act
Hanna Litwinczuk
CHAPTER 27
Some Comments from a Tax Standpoint on the Italian Implementing Provisions of Directive No. 2019/2112/EU on Cross-Border Conversions, Mergers and Divisions
Giuseppe Melis & Alessio Persiani

PART V
International Tax Law

CHAPTER 28
International Tax Treaty Law and the Renewed Role of the Pacta Sunt Servanda Rule
Carla De Pietro
CHAPTER 29
Subsequent Practice and Tax Treaties
Michael Lang
CHAPTER 30
Notes on the Application of Article 4(1) OECD Model Convention to Territorial Tax Systems
Guglielmo Maisto
CHAPTER 31
Taxation of Cross-Border Remote Workers: A Smörgåsbord of Possibilities
Katia Cejie
CHAPTER 32
Legal Form Neutrality and the Mitigation of Double Taxation of Income Earned by Entertainers and Sportspersons
Eric Kemmeren