We study how the OECD transfer pricing guidelines aimed at curbing tax-motivated transfer pricing practices affect investment incentives. Our theoretical model integrates the different OECD's transfer pricing methods into the tax planning cost function of an MNC to evaluate how the choice of...

Analysis of the international network of double tax treaties reveals a large potential for tax avoidance. Developing countries are, on average, not more likely to suffer from tax revenue losses than other countries. Yet, this average masks the fact that several countries, such as Bangladesh,...

This paper extends the sufficient statistics approach to study international tax policy. International policy differs from domestic policies because i.) from the perspective of domestic policy makers the welfare weight on foreign agents lies below that of domestic agents, and ii.) behavioral...

Border Carbon Adjustment Mechanisms (BCAMs) are becoming reality in the EU and elsewhere, and recur—in very different form—in U.S. legislative proposals. But they remain contentious, with features and differences that leave the underlying welfare rationale and implications unclear. Exploring...

This paper evaluates the Multilateral Convention to implement Pillar I Amount A, released by the OECD in October 2023, and the alternative proposal of Art. 12B for tax treaties suggested by the UN, with a particular emphasis on the perspective of developing countries. We conduct a comparative...

Taxation of cross-border services has been identified as a high priority issue in the United Nations (UN) negotiations to establish a new global framework for tax. This paper analyses the defects of international tax rules as applied to services, and their exploitation by multinational...

Multinational enterprises are increasingly using offshore locations to pay lower taxes on their profits. This behavior has distortive effects on the global economy, as the concentration of multinational activities mirrors global tax patterns. In this paper, I exploit the OECD country-by-country...

In this paper, we attempt to estimate the tax revenues to be gained by the Member States of ATAF, WATAF, AU and the South Centre under the Amount A and an alternative stylized DST taxation regime. Our research demonstrates that the comparative revenue effects of the Amount A and DST taxation...

Die Implementierung der globalen Mindeststeuer ist ein wichtiger Schritt zur Modernisierung des internationalen Steuerrechts. Sie hat aber auch Auswirkungen auf bestehende steuerliche Anreize, darunter die steuerliche Förderung von Forschung und Entwicklung. Diese werden von verschiedenen...

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS), known as the Multilateral Instrument (MLI), is an innovative multilateral method for the modification of bilateral tax treaties (BTTs). The MLI has transposed part of the...

This policy brief reflects on an underexplored proposition: that bilateral tax treaties – particularly treaties involving (middle- and) low-income countries – should contain an expiration or sunset clause. The brief examines some reasons why it may be sensible for a low-income country to...

This comprehensive study delves into the tax reforms states adopt to safeguard their tax base and assesses potential conflicts with World Trade Organization (WTO) rules. The topic gains prominence due to the growing significance of cross-border transactions on contemporary states' tax revenues....

This paper addresses a fundamental issue underlying the international tax system in the 21st century: the use of citizenship as a jurisdictional basis for imposing income tax liability. As a general matter, the United States is the only developed country that allegedly taxes its citizens living...

Intellectual Property (IP) assets enjoy a unique advantage in tax planning. Owing to their intangible nature and lack of physical substance, IP assets can be methodically parked to transfer income between tax jurisdictions. In 2016, the Delhi High Court was presented with a dispute in which IP...

Given the Republican-controlled House and narrow Democratic majority in the Senate, the Biden Administration has found itself in the perilous situation of needing to raise tax revenue while retaining the support of moderate Democrats. President Biden has proposed raising revenue by bringing the...

Drawing on narrative analysis developed by communications scholars, and applied by scholars of economics and international law and in policy analysis, this article studies action 1 of the Organisation for Economic Co-operation and Development’s (OECD’s) base erosion and profit shifting...

Developing countries around the world are facing challenges funding necessary public services such as health, education, and climate change adaptation due to a lack of revenue. Double tax treaties, which predominantly favor the allocation of taxing rights to the residence jurisdiction in...

International tax coordination has reached impressive results after the turn of the century. Multi-lateral agreements like the Common Reporting Standard or the BEPS Action Plan are clear signs of the willingness of a large number of states to cooperate in fiscal matters at a global scale....

Double taxation treaties, by assigning taxing rights to rival countries and thereby eradicating double taxation, aim to facilitate cross-border trade and investment. The eradication of double taxation is achieved through reductions in withholding tax rates on passive income in source countries,...

Shifting intellectual property (IP) rights across jurisdictions is a well-known strategy of multinationals to reduce corporate income taxation. We investigate the extent to which the flows of remunerations for the use of IP rights are affected by differences in corporate income and withholding...