Tax Reading Group (01/25)

Date:	9th January 2025
Time:	19:00-20:00 CET Time
Location:	Online
Participation link:	Microsoft Teams Need help? Join the meeting now Meeting ID: 326 955 709 322 Passcode: Fu6G2BX2
Article:	John Prebble, Ectopia, Tax Law, and International Taxation, 5 BRIT. T. REV. 383 (1997)
Click to download the article:	Article

 

How to Prepare

1)  Read the article in advance: “Ectopia, Tax Law, and International Taxation”  

 

2)   Think about one or two sentences in the article that intrigued you.

 

3)   Reflect on these guiding questions:

 

·      The author defines “ectopia” as a dislocation of income tax law from the facts to which it is related. The author further identifies “ectopic” areas in income tax laws and their transnational aspects, such as transfer pricing, CFC rules, and the WHT system. Considering recent developments in the international tax system, where do you think “ectopia” exists? 

·      The author points out that the “fictions” in income tax law, such as the concept of income itself, the concepts of source and residence, and the time segment to calculate the income tax, do not have an independent existence in the world of the physical world. These fictions are necessary for income tax law to operate. Yet, they contribute to “ectopia.” Consider whether such fiction exists under Pillar 2 (or a different topic). Do you believe these fictions are necessary, or do they create more opportunities for manipulation than they resolve? 

·      The author claims that due to “ectopia” in the income tax system, it might be impossible to construct a principled, administratively efficient, comprehensible, and inexpensive system to comply with. Do you agree with this proposition?

Meeting Format

 

1)    Welcome & Introduction (15 mins.)

 

·      A brief welcome and overview of the session

·      A concise summary of the article’s key points and arguments

·      Sharing the sentences in the article that intrigued you

 

2)   Guided Discussion (30 mins.)

 

·      Discussions around the guiding questions provided pre-meeting

 

3)   Wrap-up & Closing (15 mins.)

 

·      Summarize key takeaways

·      Final thoughts

·      Next steps

 

If you have any questions, please don’t hesitate to contact us at This email address is being protected from spambots. You need JavaScript enabled to view it.

Looking forward to an engaging and insightful discussion with you!

Best regards,

Ezgi
INTRA Tax Reading Group