The existence of different tax regimes and corporate rates of income tax between countries has given rise to international tax arbitrage and transfer pricing schemes. The objective of these schemes has been to minimize income tax expense and tax liabilities of multinational enterprises (MNEs)....

If we want to narrow the North-South divide that threatens our world, some limits on tax competition are inevitable. The world faces a crucial choice in the 2020s. We can either continue retreating from globalization in favor of xenophobic nationalism, tariffs, immigration restrictions, and...

This article examines the role that international comparisons play in current corporate tax reform discourse in the United States. Citing the need to make the U.S. corporate tax system more competitive, comparisons are frequently used to assess other jurisdictions' tax-competitiveness, and many...

[EN] “Should I stay or should I go… ”? The implementation of the EU’s internal market, characterized in the Treaty on the functioning of the European Union ( TFUE) as ”an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured”,...

[EN] “Should I stay or should I go… ”? The implementation of the EU’s internal market, characterized in the Treaty on the functioning of the European Union ( TFUE) as ”an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured”,...

This paper outlines the core issues of the introduction of a new PE nexus based on digital presence. It puts forward its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global economy. Our proposal of a new PE nexus based on digital...

The idea that a global minimum corporate income tax rate should be introduced has been publicized with great fanfare. Not as widely publicized is the fact that this, along with the other provisions of Pillar Two, has negative implications for the corporate income tax policies currently...

One of the main features of the common consolidated corporate tax base (CCCTB) Draft Directive, the formulary apportionment of the consolidated group income, leads to a significant change in corporate income taxation paradigms. Currently, corporations are taxed on a separate entity basis using...

This article assesses the impact of a Common Corporate Tax Base (CCTB) as promoted by the European Commission and the related working groups on the effective tax burdens of companies in all 27 EU Member States. The results shall help to evaluate the economic consequences of introducing a...

It is widespread practice around the world that corporate entities pay taxes to the country where they are formally registered and to the country in whose territory they generate income. While the former is generally known as the "country of residence" the latter is usually referred to as the...