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This is an introduction to the research papers that make out this Nordic Tax Journal special issue on inequality within the international tax regime. The special issue is an outcome of the discussions that took place at the (online) conference hosted by Copenhagen Business School in September 2020. In addition to introducing the papers of this special issue, this introduction also provides a contemporary guide to tax justice and tax fairness with an emphasis on theories and principles applicable to the international tax context as this was the overall theme of the conference.
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Introduction: A Contemporary Guide to Tax Justice and Tax Fairness

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The OECD Programme of Work on the tax challenges arising from the digitalization of the economy comprises a so-called GloBE (Global Base Erosion) or Pillar Two proposal, consisting of a series of measures aimed at establishing a floor to tax competition by achieving minimum taxation of the income obtained by in-scope multinational enterprises. If such a measure is implemented, developing countries would be severely deprived of the possibility to grant tax incentives to attract FDI and potentially foster economic growth. This contribution emphasizes the importance of the thorough review of their tax policy preferences that developing countries should undertake amidst the rapid adoption of GloBE, which the OECD is pushing to achieve. To illustrate this concern, an examination of implementation issues shows that a deficient enactment of the income inclusion rule proposed in GloBE could paradoxically trigger the applicability of tax sparing clauses aimed at protecting the effectiveness of tax incentives, even when both sets of rules pursue opposing goals.
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Jurisdiction Not to Tax, Tax Sparing Clauses, and the OECD Minimum Taxation (GloBE) Proposal

EU State Aid Rules as a Means of Promoting Equity within International Taxation - <italic>With a focus on inter-taxpayer equity in light of the Apple case</italic>

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This paper deals with the question whether there are reasons to deem multinational corporate groups ethically or legally responsible for paying their fair share of taxes. Ethical concepts argue that companies should generally be held responsible, but these findings contradict the mainstream market theory that understands companies as legal fictions and therefore not ethically but merely legally responsible. In contrast, we base our argumentation on the political-cultural market theory. We find that this theory provides reasons to ascribe an ethical responsibility for paying their fair share of taxes to multinational corporate groups. We argue, moreover, that this ethical responsibility also speaks for a legal responsibility. The prevailing tax law, particularly the arm's length principle, does generally not see groups as tax subjects. This currently missing legal responsibility gives reasons to rethink tax law. Therefore, we analyze whether the OECD Pillar One proposal may be an alternative to existing law.
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Research assistant at the Chair of Business Taxation

Ethical and Legal Responsibility of Multinational Corporate Groups for a Fair Share of Taxes

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Nordic Tax Journal

Call for Papers: Special Issue and Symposium of the Nordic Tax Journal: Taxing Dividends in the Nordics: Challenges and Opportunities Guest Editors: Jarkko Harju (Tampere University) and Yvette Lind (BI Norwegian Business School)  The winner of the 2023 Nordic Tax Council´s Article Prize can be found here.  Nordic Tax Journal is a peer reviewed, open access journal that publishes original, scholarly works on all aspects of taxation. It aims to promote contemporary research of tax-related issues, from both legal and economic perspectives, and to provide a platform for academics, researchers, practitioners, administrators, judges and policy makers to enhance their understanding and knowledge of taxation in the Nordic region. Although we appreciate a Nordic angle in manuscripts, it is not a requirement.  Nordic Tax Journal is published by the Nordic Tax Research Council, a resource for academics, tax officials, practitioners and policymakers pursuing high quality tax research throughout the Nordic region.  The articles in Nordic Tax Journal are published continuously throughout the year. It is abstracted and indexed in numerous relevant services (listed under the "Abstracting &amp; Indexing" tab), and ranked among the top law/economic journals in the Nordic region. The journal does not have article processing charges (APCs) or article submission charges.  Contributors are encouraged to submit their manuscripts to Nordic Tax Journal through its electronic submission system Editorial Manager.  The Nordic Tax Research Council's ARTICLE PRIZE €3.000The Nordic Tax Research Council's Article Prize is awarded yearly to the author of an article published in Nordic Tax Journal (NTaxJ).As from 2019 a prize of 3.000 EUR is awarded at the Council's annual spring seminar, by the Council Chair and the Editor-in-Chief of Nordic Tax Journal. The assessment criteria for the Article Prize are the same as for publication in Nordic Tax Journal: high quality research on taxation relevant to the Nordic countries. Authors can apply to enter the contest when submitting a manuscript to NTaxJ.  Nordic Tax Journal is ranked on the following Nordic academic lists:   Top rankDanish Ministry of Higher Education and Science (Page 185)   Scientific Level 1Norwegian Social Science Data Services   Level 1Publication Forum Federation of Finnish Learned Societies Visit our FacebookVisit our Twitter  Archiving  Sciendo archives the contents of this journal in Portico - digital long-term preservation service of scholarly books, journals and collections.  Plagiarism Policy  The editorial board is participating in a growing community of Similarity Check System's users in order to ensure that the content published is original and trustworthy. Similarity Check is a medium that allows for comprehensive manuscripts screening, aimed to eliminate plagiarism and provide a high standard and quality peer-review process.  Target group   academics, researchers, practitioners, administrators, judges and policy makers interested in the taxation systems in the Nordic region 

Nordic Tax Journal

Volume 2021 (2021): Issue 1 (October 2021)

Article

Introduction: A Contemporary Guide to Tax Justice and Tax Fairness

Jurisdiction Not to Tax, Tax Sparing Clauses, and the OECD Minimum Taxation (GloBE) Proposal

EU State Aid Rules as a Means of Promoting Equity within International Taxation - With a focus on inter-taxpayer equity in light of the Apple case

Ethical and Legal Responsibility of Multinational Corporate Groups for a Fair Share of Taxes

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