Almand, K. and Sayers, D. (2009), ‘Hot Topics in Thin Capitalisation’, Tax Journal, 968, pp. 5–6Google Scholar

Arginelli, P. and Innamorato, C. (2008), ‘Italy: The Interaction between Tax Treaties and Domestic Law: An Issue of Constitutional Legitimacy’, European Taxation, June, pp. 299–304

Arnold, B. (2004), ‘Tax Treaties and Tax Avoidance: The 2003 Revisions to the Commentary to the OECD Model’, International Tax Bulletin, 58, 6, pp. 244–60Google Scholar

Arnold, B (2006), ‘At Sixes and Sevens: The Relationship between the Taxation of Business Profits and Income from Immovable Property under Tax Treaties’, International Tax Bulletin, 60, 1, pp. 5–18Google Scholar

Arnold, B (2008), ‘New Services PE Rule in the Canada–U.S. Treaty Protocol’, Worldwide Tax Daily, 15 July, 2008 WTD 136–8

Arnold, B. and McIntyre, M. (2002), International Tax Primer, 2nd edn (The Hague: Kluwer Law International)Google Scholar

Ault, H. and Arnold, B. (eds.) (2010), Comparative Income Taxation: A Structural Analysis, 3rd edn (The Netherlands: Kluwer Law International)

Ault, H. and Sasseville, J. (2009), ‘2008 OECD Model: The New Arbitration Provision’, Bulletin for International Taxation, 63, 5/6, pp. 208–15Google Scholar

Avery Jones, J. (1991), ‘Bodies of Persons’, British Tax Review, pp. 453–65

Avery Jones, J (1999), ‘The Relationship between the Mutual Agreement Procedure and Internal Law’, EC Tax Review, 8, 1, pp. 4–7Google Scholar

Avery Jones, J (2005), ‘Place of Effective Management as a Residence Tie-Breaker’, Bulletin for International Fiscal Documentation, 59, 1, pp. 20–4Google Scholar

Avery Jones, J (2009), ‘2008: OECD Model: Place of Effective Management – What One Can Learn from the History’, Bulletin for International Taxation, 63, 5/6, pp. 183–6Google Scholar

Avery Jones, J., Baker, P., Broe, L. et al. (2009), ‘The Definitions of Dividends and Interest in the OECD Model: Something Lost in Translation?’, British Tax Review, pp. 406–52

Avery Jones, J., Depret, H., Wiele, M. et al. (1991), ‘The Non-Discrimination Article in Tax Treaties’, British Tax Review, Part I pp. 359–85, Part II pp. 421–52Google Scholar

Avery Jones, J., Broe, L., Ellis, M. et al. (2006), ‘The Origins of Concepts and Expressions Used in the OECD Model and Their Adoption by States’, British Tax Review, pp. 695–765Google Scholar

Avery Jones, J., Harris, P. and Oliver, D. (eds.) (2008), Comparative Perspectives on Revenue Law: Essays in Honour of John Tiley (Cambridge, UK: Cambridge University Press)CrossRef

Avi-Yonah, R. (2007), ‘What Can the U.S. Supreme Court and the European Court of Justice Learn from Each Other's Tax Jurisprudence?’, 3 December, available at SSRN http://ssrn.com/abstract=1048821 accessed 17 March 2010

Avi-Yonah, R (2009), ‘Xilinx and the Arm's-Length Standard’, Worldwide Tax Daily, 9 June, 2009 WTD 108-1

Avi-Yonah, R. and Clausing, K. (2007), ‘A Proposal to Adopt Formulary Apportionment for Corporate Income Taxation: The Hamilton Project’, University of Michigan Law & Economics, Olin Working Paper No. 07–009, available at SSRN http://ssrn.com/abstract=995202 accessed 17 March 2010

Baker, P. (2000), ‘Taxation and the European Convention on Human Rights’, British Tax Review, pp. 211–377

Baker, P (2001–), Double Taxation Conventions: A Manual on the OECD Model Tax Convention on Income and on Capital (London: Sweet & Maxwell)Google Scholar

Baker, P (2008), ‘Taxation, Human Rights and the Family’, in Avery Jones, Harris and Oliver (eds.), pp. 232–43CrossRef

Barnard, C. (2007), The Substantive Law of the EU: The Four Freedoms, 2nd edn (Oxford: Oxford University Press)Google Scholar

Brooks, K. (2008), Inter-Nation Equity: The Development of an Important but Underappreciated International Tax Value', in Krever, R. and Head, J., Tax Reform in the 21st Century (London: Kluwer Law International), available at SSRN http://ssrn.com/abstract=1292370 accessed 17 March 2010Google Scholar

Burns, L. and Krever, R. (1998), ‘Individual Income Tax’, in Thuronyi, V. (ed.), Tax Law Design and Drafting, Vol. 2 (Washington DC: IMF), Chapter 14, pp. 495–563Google Scholar

Cooklin, J. (2008), ‘Corporate Exodus: When Irish Eyes are Smiling’, British Tax Review, pp. 613–23

Daunton, M. (2008), ‘Land Taxation, Economy and Society in Britain and its Colonies’, in Avery Jones, Harris and Oliver (eds.), pp. 197–218CrossRef

Desai, M. and Hines, J. (2003), ‘Economic Foundations of International Tax Rules’, a paper prepared for the American Tax Policy Institute, Washington DC, December, available at www.americantaxpolicyinstitute.org/pdf/economic_foundation_internal.pdf accessed 17 March 2010

Desai, M. and Hines, J. (2004), ‘Old Rules and New Realities: Corporate Tax Policy in a Global Setting’, Ross School of Business Paper No. 920, October, available at SSRN http://ssrn.com/abstract=606222 accessed 17 March 2010

Drevet, S.A. and Thuronyi, V. (2009), ‘The Tax Treaty Network of the U.N. Member States’, Worldwide Tax Daily, 3 June, 2009 WTD 104-12

,European Commission (2001), ‘Company Taxation in the Internal Market’, COM(2001)582 final

,European Commission (2004), ‘European Tax Survey’, Commission Staff Working Paper, SEC(2004)1128

,European Commission (2006), ‘Communication on the Tax Treatment of Losses in Cross-Border Situations’, COM(2006)824 final

,European Commission (2007a), ‘Communication on the work of the EU Joint Transfer Pricing Forum in the Field of Dispute Avoidance and Resolution Procedures and on Guidelines for Advance Pricing Agreements within the EU’, COM(2007)71

,European Commission (2007b), ‘Communication on the Application of Anti-Abuse Measures in the Area of Direct Taxation – within the EU and in Relation to Third Countries’, COM(2007)785

,European Commission (2008), ‘Corporate Taxation: Commission Requests the United Kingdom to Properly Implement an ECJ Ruling on Cross-Border Loss Compensation’, Press Release IP/08/1365

,European Commission (2009a), ‘Proposal for a Council Directive Concerning Mutual Assistance for the Recovery of Claims Relating to Taxes, Duties and Other Measures’, COM(2009)28

,European Commission (2009b), ‘Proposal for a Council Directive on Administrative Cooperation in the Field of Taxation’, COM(2009)29

,European Parliament (2008a), ‘Report on the Impact of the Rulings of the European Court of Justice in the Area of Direct Taxation’, Press Release IP/A/ECON/ST/2007–27

,European Parliament (2008b), ‘EU Action Needed on Tax Treatment of Cross-border Corporate Losses’, Press Release 20080111IPR18259

,European Parliament (2009), ‘Resolution of 10 March 2009 with Recommendations to the Commission on the Cross-border Transfer of the Registered Office of a Company’, 2008/2196(INI)

,European Union (1997), ‘Resolution of the Council and the Representatives of the Governments of the Member States, Meeting within the Council of 1 December 1997 on a Code of Conduct for Business Taxation’, in van Raad (ed.) (2009), pp. 2346–53

,European Union (1999), ‘Report on the Code of Conduct (Business Taxation)/Primarolo Group’, in van Raad (ed.) (2009), pp. 2354–62

,European Union (2005), ‘Code of Conduct for the Effective Implementation of the Arbitration Convention’, 2695/2/04 REV 2, in van Raad (ed.) (2009), pp. 2280–85

,European Union (2008), ‘Council Resolution on Coordinating Exit Taxation’, 2911th Economic and Financial Affairs, Brussels, 2 December

,Finance Ministers (2009), ‘Finance Ministers Issue Statement on International Tax Fraud and Evasion’, Worldwide Tax Daily, 23 June, 2009 WTD 119–21

Fraser, R. (2001), ‘Respectez les animaux étrangers! The Inland Revenue List on Entity Classification’, British Tax Review, pp. 158–61

Fraser, R and Oliver, J.D. (2007), ‘Beneficial Ownership: HMRC's Draft Guidance on Interpretation of the Indofood Decision’, British Tax Review, pp. 39–57Google Scholar

Fuller, J. (2008), ‘U.S. Tax Review’, Worldwide Tax Daily, 30 July, 2008 WTD 147–10

Gnaedinger, C. (2003), ‘EU Critiques Accession States’ Company Tax Rules', Worldwide Tax Daily, 23 July, 2003 WTD 141-1

Gnaedinger, C (2006), ‘European Commission Disagrees with ECJ on Double Taxation’, Worldwide Tax Daily, 16 November, 2006 WTD 221-3

Gordon, K. (2004), ‘Interpreting Statutes’, Taxation, 152, 3946, 26 February, pp. 506–8

Gutmann, D., Austry, S. and Roux, P. (2009), ‘Tax Treatment of Foreign Pension Funds’, European Taxation, 49, 1, pp. 21–8Google Scholar

Harris, P. (1996), Corporate/Shareholder Income Taxation and Allocating Taxing Rights Between Countries: A Comparison of Imputation Systems (Amsterdam: IBFD)Google Scholar

Harris, P (1999), ‘An Historic View of the Principle and Options for Double Tax Relief’, British Tax Review, pp. 469–89

Harris, P (2000), ‘Origins of the 1963 OECD Model Series: Working Party 12 and Article 10’, Australian Tax Forum, 15, pp. 3–223Google Scholar

Harris, P (2006), Income Tax in Common Law Jurisdictions: From the Origins to 1820 (Cambridge, UK: Cambridge University Press)CrossRefGoogle Scholar

Harris, P (forthcoming), Income Tax in Common Law Jurisdictions: 1820 to Present

Harris, P. and Oliver, J.D. (2008), ‘Family Connections and the Corporate Entity: Income Splitting through the Family Company’, in Avery Jones, Harris and Oliver (eds.), pp. 244–87

,HMRC (2007), ‘Changes to Controlled Foreign Companies Rules’, Draft Guidance, 17 December

,HMRC and HM Treasury (2010), ‘Proposals for Controlled Foreign Companies (CFC) Reform: Discussion Document’, January 2010

,International Monetary Fund (2009), ‘IMF Report Analyzes Effects of Debt Bias in Tax Policy’, Worldwide Tax Daily, 12 June, 2009 WTD 114-16

Jackson, R. (2008a), ‘More Tax Cheats in Doghouse Over Liechtenstein Tax Evasion’, Worldwide Tax Daily, 31 March, 2008 WTD 62-2

Jackson, R (2008b), ‘Germany Eases Rule for Deducting Cross-Border Losses’, Worldwide Tax Daily, 6 August, 2008 WTD 152-01Google Scholar

Jackson, R (2008c), ‘Henderson Global Investors to Leave U.K. for Ireland’, Worldwide Tax Daily, 29 August, 2008 WTD 169-4Google Scholar

Kandev, M.N. and Wiener, B. (2009), ‘Some Thoughts on the Use of Later OECD Commentaries after Prévost Car’, Worldwide Tax Daily, 1 June, 2009 WTD 102-15

Karyadi, F. (2007), ‘Indonesian Supreme Court Nullifies Treaty Shopping Practice’, Worldwide Tax Daily, 26 February, 2007 WTD 38-4

Kent, R. (1999), ‘Entity Classification – Oxnard Financing SA v Rahn and Others’, British Tax Review, pp. 125–8

Kingston, S. (2007), ‘A Light in the Darkness: Recent Developments in the ECJ's Direct Tax Jurisprudence’, Common Market Law Review, 44, 5, pp. 1321–59Google Scholar

Klauson, I. (2008), ‘ECJ Sides with Estonia in Burda Case’, Worldwide Tax Daily, 9 July, 2008 WTD 132-6

Lang, M. (2004), Double Non-taxation, International Fiscal Association, Cahiers de droit, Vol. 89a (Amersfoort: Sdu Fiscale & Financiële Uitgevers)Google Scholar

Lang, M., Herdin, J. and Hofbauer, I. (eds.) (2005), WTO and Direct Taxation, Eucotax Series on European Taxation, vol. 10 (The Hague: Kluwer Law International)Google Scholar

McDaniel, P.R. (2004), ‘The David R. Tillinghast Lecture: Trade Agreements and Income Taxation: Interactions, Conflicts, and Resolutions’, Tax Law Review, 57, 2, pp. 275–300Google Scholar

Mason, R. (2008), ‘Made in America for European Tax: The Internal Consistency Test’, Boston College Law Review, 49, 5, pp. 1277–326Google Scholar

Malgari, D. (2008), ‘Denmark Terminates Tax Treaties with France, Spain’, Worldwide Tax Daily, 13 June, 2008 WTD 115-3

Monti, M. (2003), ‘EU Commissioner Monti Discusses State Tax Aid’, Worldwide Tax Daily, 26 May, 2003 WTD 103-12

O'Brien, M. (2008), ‘Taxation and the Third Country Dimension of Free Movement of Capital in EU Law: The ECJ's Rulings and Unresolved Issues’, British Tax Review, pp. 628–66

,OECD (1992–), Model Tax Convention on Income and on Capital, Committee on Fiscal Affairs (Paris: OECD)Google Scholar

,OECD (1995–2000), Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (Paris: OECD)Google Scholar

,OECD (1998), Harmful Tax Competition: An Emerging Global Issue (Paris:OECD)Google Scholar

,OECD (2003), ‘Are the Current Treaty Rules for Taxing Business Profits Appropriate for e-Commerce?’, discussion draft of 26 November 2003, in van Raad (ed.) (2005), pp. 798–857

,OECD (2007), ‘Application and Interpretation of Article 24 (Non-discrimination)’, discussion draft of 3 May 2007, in van Raad (ed.) (2009), pp. 850–73

,OECD (2008a), Report on the Attribution of Profits to Permanent Establishments (Paris: OECD)Google Scholar

,OECD (2008b), ‘Draft Alternative Article 7 of the OECD Model Tax Convention and Related Commentary’, discussion draft of 7 July 2008, in van Raad (ed.) (2009), pp. 753–79

,OECD (2008c), ‘Transfer Pricing Aspects of Business Restructurings’, discussion draft of 19 September 2008 (Paris: OECD)Google Scholar

,OECD (2008d), OECD in Figures: 2008 (Paris: OECD)Google Scholar

,OECD (2009), ‘OECD Issues Brief on International Tax Evasion’, Worldwide Tax Daily, 21 April, 2009 WTD 82-21

Oliver, J.D. (1998), ‘Ship-Money’, British Tax Review, pp. 1–3

Oliver, J.D (2000), ‘Entitlement of a Permanent Establishment to Third State Treaty Benefits: Saint-Gobain’, British Tax Review, pp. 174–81

Oliver, J.D (2001), ‘Effective Management’, British Tax Review, pp. 289–95

O'Shea, T. (2007), ‘ECJ and Taxation of Residents and Nonresidents – Deduction of Expenses’, Worldwide Tax Daily, 10 May, 2007 WTD 91-9

Owen, P. (2003), ‘Can Effective Management be Distinguished from Central Management and Control?’, British Tax Review, pp. 296–305

Parillo, K. (2009), ‘CCCTB Proposal Postponed Until at Least End of 2009’, Worldwide Tax Daily, 2 February, 2009 WTD 19-1

Raad, K. (ed.) (2005), 2005/06 Materials on International and EC Tax Law (Leiden: International Tax Center)

Raad, K. (ed.), (2009), 2009/10 Materials on International and EC Tax Law (Leiden: International Tax Center)

Reeb-Blanluet, S. (2007), ‘France Releases Guidance on New CFC Tax Regime’, Worldwide Tax Daily, 2 February, 2007 WTD 23-1

Sasseville, J. (2008), ‘Treaty Recognition of Groups of Companies’, in Maisto, G. (ed.), International and EC Tax Aspects of Groups of Companies, EC and International Tax Law Series, Vol. 4 (Amsterdam: International Bureau of Fiscal Documentation), pp. 129–36Google Scholar

Schön, W. (2004), ‘World Trade Organization Law and Tax Law’, Bulletin for International Fiscal Documentation, 58, 7, pp. 283–96Google Scholar

Schön, W (2008), ‘Abuse of Rights and European Tax Law’, in Avery Jones, Harris and Oliver (eds.), pp. 75–98CrossRef

Scott, C. (2004), ‘OECD Targets Additional Financial Centers in Expanded Tax Haven Crackdown’, Worldwide Tax Daily, 7 June, 2004 WTD 109-1

Sheppard, L. (2005), ‘U.K. Goes After Deferred Subscription Arrangements’, Worldwide Tax Daily, 4 April, 2005 WTD 63-4

Sheppard, L (2006), ‘European Union: Year in Review’, Worldwide Tax Daily, 10 January, 2006 WTD 6-6

Six, M. (2009), ‘Hybrid Finance and Double Taxation Treaties’, Bulletin for International Taxation, 63, 1, pp. 22–5Google Scholar

Smith, A.S. (1776), An Inquiry into the Nature and Causes of the Wealth of Nations, Vol. 36 of Adler, M.J. (ed.) (1990), Great Books of the Western World, 2nd edn. (Chicago: Encyclopedia Britannica Inc.)CrossRefGoogle Scholar

Terra, B. and Wattel, P. (2008), European Tax Law, 5th edn (London: Kluwer Law International)Google Scholar

Thiel, S. (2008), ‘European Union: Justifications in Community Law for Income Tax Restrictions on Free Movement: Acte Clair Rules That Can Be Readily Applied by National Courts’, European Taxation, 48, 6 and 7, pp. 279–90 and 339–50Google Scholar

Tiley, J. (2008), Revenue Law, 6th edn (London: Hart Publishing)

Tiley, J (2010), ‘United Kingdom’, in Ault, and Arnold, (eds.), pp. 145–72

,United Nations (2001), United Nations Model Double Taxation Convention between the Developed and Developing Countries (New York: United Nations)Google Scholar

,United States (2006), United States Model Income Tax Convention (15 November 2006)

,United States Internal Revenue Service (2009), ‘U.S. Regs’ Treatment of Interest Does Not Violate Treaty', Worldwide Tax Daily, 24 April, 2009 WTD 33-28

Vann, R. (2003), ‘Reflections on Business Profits and the Arm's-Length Principle’, in B. Arnold, J. Sasseville and Zolt, E. (eds.), The Taxation of Business Profits under Tax Treaties (Toronto: Canadian Tax Foundation), pp. 133–69Google Scholar

Vann, R. (2006), ‘Tax Treaties: The Secret Agent's Secrets’, British Tax Review, pp. 345–82

Vann, R (2008), ‘The History of Royalties in Tax Treaties 1921–61: Why?’, in Avery Jones, Harris and Oliver (eds.), pp. 166–96CrossRef

Vogel, K. (1997), Klaus Vogel on Double Taxation Conventions, 3rd edn (Boston: Kluwer Law International)Google Scholar

Weiner, J. (2008), ‘OECD Updates Model Tax Convention’, Worldwide Tax Daily, 1 July, 2008 WTD 127-1