Residence, Multinational Enterprises and BEPS: Is Determining the Residence of Companies Belonging to Multinational Groups Mission Impossible?

Irene Burgers; Raymond Adema; Maarten de Wilde

Residence, Multinational Enterprises and BEPS: Is Determining the Residence of Companies Belonging to Multinational Groups Mission Impossible?

Irene Burgers, Raymond Adema, Maarten de Wilde

Protecting European Citizens and Market Participants

Research output: Chapter in Book/Report/Conference proceeding › Chapter › Academic

Abstract

The authors argue it is not so much imposible to draft theoretically well founded definitions for determining the residence of companies, but to effectively address tax base erosion and other tax planning. A "substance-safe harbour" may result in "substance tax planning"and "substance competition".

Original language	English
Title of host publication	Corporate Tax Residence and Mobility
Editors	Edoardo Traversa
Place of Publication	Amsterdam
Publisher	IBFD
Chapter	4
Pages	105-134
ISBN (Print)	978-90-8722-451-6
Publication status	Published - 2018
Event	2017 European Association of Tax Law Professors Congress: EATLP - Faculty of Law and Administration University of Lodz, Lodz, Poland Duration: 1-Jun-2017 → 3-Jun-2017 http://www.eatlp.org/congresses/this-years-congress/286-2017-eatlp-congress-1-3-june-in-lodz-poland

Publication series

Name	EATLP International Tax Series
Number	826
Volume	16
ISSN (Print)	1574-9789

Conference

Conference	2017 European Association of Tax Law Professors Congress
Country	Poland
City	Lodz
Period	01/06/2017 → 03/06/2017
Internet address	http://www.eatlp.org/congresses/this-years-congress/286-2017-eatlp-congress-1-3-june-in-lodz-poland

Embargoed Document

BW_CORPORATE_TAX_RECIDENCY_EATLP_SERIES_v2
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Cite this

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title = "Residence, Multinational Enterprises and BEPS: Is Determining the Residence of Companies Belonging to Multinational Groups Mission Impossible?",

abstract = "The authors argue it is not so much imposible to draft theoretically well founded definitions for determining the residence of companies, but to effectively address tax base erosion and other tax planning. A {"}substance-safe harbour{"} may result in {"}substance tax planning{"}and {"}substance competition{"}.",

author = "Irene Burgers and Raymond Adema and {de Wilde}, Maarten",

year = "2018",

language = "English",

isbn = "978-90-8722-451-6",

series = "EATLP International Tax Series ",

publisher = "IBFD",

number = "826",

pages = "105--134",

editor = "Edoardo Traversa",

booktitle = "Corporate Tax Residence and Mobility",

note = "2017 European Association of Tax Law Professors Congress : EATLP ; Conference date: 01-06-2017 Through 03-06-2017",

url = "http://www.eatlp.org/congresses/this-years-congress/286-2017-eatlp-congress-1-3-june-in-lodz-poland",

}

Burgers, I , Adema, R & de Wilde, M 2018, Residence, Multinational Enterprises and BEPS: Is Determining the Residence of Companies Belonging to Multinational Groups Mission Impossible? in E Traversa (ed.), Corporate Tax Residence and Mobility. EATLP International Tax Series , no. 826, vol. 16, IBFD, Amsterdam, pp. 105-134, 2017 European Association of Tax Law Professors Congress, Lodz, Poland, 01/06/2017.

Residence, Multinational Enterprises and BEPS: Is Determining the Residence of Companies Belonging to Multinational Groups Mission Impossible? / Burgers, Irene ; Adema, Raymond; de Wilde, Maarten.

Corporate Tax Residence and Mobility. ed. / Edoardo Traversa. Amsterdam : IBFD, 2018. p. 105-134 (EATLP International Tax Series ; Vol. 16, No. 826).

Research output: Chapter in Book/Report/Conference proceeding › Chapter › Academic