This article compares and contrasts three specific proposals that allocate taxing rights to market countries: (i) the OECD's "Unified Approach" (Pillar One); (ii) the United Nations' "Article 12B"; and (iii) Devereux et al.'s "residual profit allocation by income". The article aims to identify...

This article surveys the evolution of the discussion on tax and digitalization between 1996 and 2018, analysing the shifts in thinking over this period and their impact going forward. Particular attention is given to four themes that emerge in this discussion. These are the changes in thinking...

This article provides some preliminary thoughts on tax policy and the COVID-19 crisis. In the first part, it discusses fiscal measures available to policymakers in response to the COVID-19 crisis. The role of taxation will evolve over the different phases of the pandemic: measures have already...

"Banks seem all too often involved in cases of misconduct, particularly involving the exploitation of tax systems. 'Banking on Failure' explains why and how banks "game the system", accounting for these misconduct cases and analysing the wider implications for financial markets and tax...

This is the first book to present a sustained analysis and critique of arm's length based transfer pricing rules following the G20 / OECD Base Erosion and Profit Shifting (BEPS) project. The book considers the nature and scope of transfer pricing rules based on the arm's length principle...