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...

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...

This paper reveals how tax complexity, in the form of loopholes and assets overlapping different sections of tax returns, contributes to tax avoidance and evasion. Using administrative data from the Netherlands, it shows how an auditing announcement in 2005 triggered large increases in declared...

This paper aims to describe the state of multilateral and unilateral efforts to tax digital services; summarize the state of economic analysis on digital services taxes; and provide an overview of where the Philippines stands in relation to other countries in digital service taxation. On-going...

The taxation of the digitalized economy is the single most important topic in international tax negotiations today. The OECD has devised a "Two Pillar solution" to the problem. Pillar One is focusing on a reallocation of taxing rights to market jurisdictions, which are largely expected to be...

The proposed OECD Pillar One and Two reforms mark a significant shift in the way large multinational enterprises are taxed on their global incomes. However, while considering the reform at the proposed scale tax administrators must be able to compare the revenue gains with alternatives. This...

The Research Paper commences with an overview of Pillar One and Pillar Two followed by detailed discussions on salient provisions of Pillar Two. Pillar Two is envisaged to have a widespread impact on Small Island Developing States (SIDS) which are a distinct group of 38 United Nations (UN)...

The study aims to evaluate the country's legal framework for taxing digital transactions. Specifically, the extent to which the provisions of the law can map onto the value of digital markets. Based on the findings on the structure of the digital commerce value chain, and its possible...

In this research paper, we attempt to estimate the tax revenues to be gained (or lost) by the South Centre and African Union's Member States under the Amount A and Article 12B regimes. Our analysis relied on sources of information available to private sector researchers but did not involve...

Domestic resource mobilization is essential for developing countries to achieve the Sustainable Development Goals by the deadline of 2030. Concomitantly, Illicit Financial Flows (IFFs), which also lead to asset theft, are major means through which these countries are losing resources. This...

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...

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...

Weisen allgemeine Antimissbrauchsvorschriften verschiedener Steuersysteme trotz unterschiedlicher Ausgestaltung mehr Ähnlichkeiten auf als es zunächst scheint? Um diese Frage zu beantworten, befasst sich die Autorin in ihrer Arbeit mit dem Recht Hongkongs, Singapurs und der Volksrepublik China...

The main goal of this study is to assess whether, and if so, how the tax policy is implemented in Poland in relation to informal partnerships. The justification for conducting research in this area is the growing number of such relationships and the demands formulated by the public on the...

The paper discusses the European Commission’s tax policy agenda in business income taxation and the ongoing legislative initiatives in this regard as per early 2022. The focus is on the Commission Communication titled ‘Business Taxation for the 21st Century’ of 18 May 2021 and the...

A government's primary duty is to provide its people with public services, for which it needs funding to cover its costs. Taxation, among other things, serves as a significant source of funding for public spending. The government has been able to uncover new avenues for revenue collection...

This is the fifteenth in a series of sixteen papers about the U.S extraterritorial tax system.This article:- Cautions against any new U.S. tax system that would perpetuate the constitutional and human rights violations of the current system; - Explains how other countries are able to further the...

GPT-4 performs vastly better than ChatGPT or GPT-3.5 on legal tasks like the bar exam and statutory reasoning. To test GPT-4’s abilities, we ran it on our final exams this semester and graded its output alongside students’ exams. We found that it produced smoothly written answers that failed...

Taxation is one of the few things that we can take as a given in life. People will always look for ways to minimize the tax burdens that governments seek to impose on them. Indeed, there is a very well-developed industry devoted to that end. How should governments proceed? We develop an economic...

This article presents an overview of the history of tax dispute resolution in Canada. It traces the history of Canada’s system of tax dispute resolution through eight distinct phases from 1918 through to the present-day operation of the Tax Court of Canada. With this history outlined,...

This Essay is based on my presentation to Temple University Beasley School of Law for the 2022 Frank and Rose Fogel Lecture Series. This is not intended to be a transcript of my remarks given on October 11, 2022, but instead, an opportunity to provide additional information regarding the Tax...

This paper seeks to identify two key differences between the U.S. tax law and Nigerian tax law with the aim of comparing the different approaches identified and commenting on what each country might learn from the other country’s approach. For this purpose, it was necessary to, first, identify...

Das Werk behandelt das „Bezahlen mit Daten“ aus umsatzsteuerrechtlicher Sicht. Ausgehend von der (steuer)rechtlichen Einordnung künstlicher Intelligenz werden die Auswirkungen des Einsatzes künstlicher Intelligenz in Geschäftsmodellen auf das bestehende Besteuerungssystem dargestellt und...

Tax planning is part of modern financial management worldwide, and the countries of Central Europe are no exception. Tax havens provide opportunities for managers to increase companies profits through tax reduction. Naturally, there are differences in ownership structures; therefore, the...

We examine an international panel of domestic firms to quantify the degree to which conforming tax avoidance changes with statutory tax rates. We derive an alternative estimation method that identifies conforming tax avoidance from the variation of tax rates over time and across countries. We...

The Earned Income Tax Credit, a federal anti-poverty program administered through the tax system, provides a total of about $65 billion a year in “refundable credits” (a payment in excess of tax liability) to more than 25 million working low-income taxpayers, who receive an average of about...