Showing 1 - 10 of 286,395
, and still is, the creation of an exclusionary architecture that deprives the majority of the world's countries from … League of Nations and the OECD. Rejecting old and new solutions for a just world tax order, what the author believes is … actually needed is a completely different approach, grounded on contested multilateral practices and diversity of world views …
Persistent link: https://www.econbiz.de/10012850615
Tax scholarship typically presumes the state’s power to tax and therefore rarely concerns itself with analyzing which relationships between a government and a potential taxpayer normatively justify taxation, and which do not. This paper presents the case for undertaking such an analysis as a...
Persistent link: https://www.econbiz.de/10014122675
Why do countries follow the rules they do for international taxation? Tax scholarship is increasingly using terms like hard law and soft law to explain the degree of global adherence to various tax practices. In this brief essay, I make the case that terms we use are important because they...
Persistent link: https://www.econbiz.de/10012776892
This analysis refers to the emergence of so-called Advance Pricing Agreements (APA) in international taxation and corresponding APA programs in individual countries. APAs are a type of non-bureaucratic, cooperative governance that exists between the multinational corporate taxpayer and the...
Persistent link: https://www.econbiz.de/10012783410
This study was drafted as the EU topical report for IFA's general report on the topic reconstructing the treaty network and deals with the intersection of three areas: i) European Union law; ii) the OECD's Base Erosion and Profit Shifting project (BEPS) and its implementation, and; iii) member...
Persistent link: https://www.econbiz.de/10014095441
The existing double taxation agreement between the United Kingdom of Great Britain and Northern Ireland and the Polish People's Republic (signed back in 1976 amidst a political and economic détente promoted by the relatively liberal and progressive – on a COMECON scale – communist...
Persistent link: https://www.econbiz.de/10013002181
Tax policy in general and international income tax policy in particular has long been a subject of discussion and argument by tax philosophers, economists, and lawyers. Theories have often been introduced to support the establishment of new tax systems, to justify existing ones, or to call for...
Persistent link: https://www.econbiz.de/10013083816
This chapter for a forthcoming text on investment promotion explains the concept of “luring with tax”. It first lays out in broad strokes how nation states compete with each other for direct and portfolio investment using their tax systems. It then analyzes whether using the tax system as an...
Persistent link: https://www.econbiz.de/10012988954
This document contains four installments of "The Big Picture," a column published in Tax Analysts, International Tax Notes, Volumes 66-68 (2012). The first installment, "Putting Arbitration on the MAP: Thoughts on the New U.N. Model Tax Convention," discusses the addition of mandatory...
Persistent link: https://www.econbiz.de/10013086360
Conventional wisdom explains tax competition as an external constraint on lawmaking that can only be curbed through multinational cooperative efforts to eliminate beggar-thy-neighbor tax policies. But the international tax reform plan recently introduced by Senator Baucus squarely confronts this...
Persistent link: https://www.econbiz.de/10013061070