Luca Dell’anese-Egea has published Tax Arbitrage and the Changing Structure of International Tax Law (2006). Here is the puboisher’s description:
The present work ia s tax policy analysis of international tax arbitrage. Tax arbitrage occurs when a tax-payer engages in a transaction or set up a business structure to take advantage of differences among country tax systems – usually inconsistencies in addressing a cammon tax question – with the goal of exploiting them in order to duplicate tax benefits and to minimize his overall tax burden. The possibility to arbitrage differences among tax jurisdictions arises when two countries characterize transactions inconsistently. The book focuses its attention on the most popular tax arbitrage techniques, describes their tax policy ramifications and shows the worrisome implications that these planning devices have on the integrity of the international tax regime. Particular attention is paid to the attempts of different tax jurisdictions to restrain tax arbitrage through the implementation of ad hoc legislative solutions. The book develops a general theoretical framework for the understanding of international tax arbitrage and identifies possible forms of tax coordination among different countries able to reduce those normative inconsistencies among jurisdictions which represent the most fertile ground for the development of tax arbitrage.
(Hat Tip: Reuven Avi-Yonah.)




