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...

Using unique tax audit data of 499 German firms, we analyze whether family firms, public firms, financially constrained firms, and those firms with managers with low tax morale substitute two tax strategies, book-tax conforming and nonconforming tax avoidance strategies, and examine the effect...

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...

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...

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)...

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...

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...

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 research investigates the impact of tax justice perception and tax understanding on the compliance of Small and Medium-sized Enterprises (SMEs) with government regulation Number 55, 2022, in Surabaya. The study, conducted at KPP Pratama Surabaya Wonocolo employs a quantitative approach,...

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...

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...

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...

The purpose of this article is to study the tax sustainability of agricultural companies in Ukraine. This article developed the following working hypotheses, which were derived from the main purpose of the study. The methodology for the assessment of tax sustainability has been improved due to...

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...

Countries wishing to reform their tax system must consider that their proposals are in line with both international trade law and international tax law, which, if on the one side, are two different branches of international law, on the other side, they share overlapping elements in relation to...

This is the tenth in a series of sixteen papers about the U.S extraterritorial tax system.The U.S. extraterritorial tax system violates multiple provisions of international human rights instruments that have been signed, or signed and ratified, by the United States. The rights in question...

As democracies around the world have faltered, legal scholars in fields as diverse as election law, labor law, and administrative law have turned to tax law to repair and support democratic governments. Taxation offers a toolset well equipped to address concerns raised by democratic theorists...

Sri Lanka’s taxation has two key burning issues. One is the consistent reduction of tax to GDP ratio over the last three decades, which reached its lowest of 8.4 in 2020 (CBSL,2020). This means the government revenue is extremely low, resulting in persistent budget deficits. The second issue...

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...