Complaints in society about how multinationals pay corporate tax are familiar. Multinationals seem able to arrange their affairs in a way that allows them to avoid contributing their fair share. Governments help them to attract investment. Workers and customers, meanwhile, face ever-increasing...

The current international corporate tax regime for taxing the business proceeds of firms operates arbitrarily. The aggregates of the nation states' international corporate tax systems seem to distort a global efficient allocation of resources. The model is ill-suited to current market realities....

In this paper, the author sets out a proposal for an alternative, more neutral system for taxing multinationals. His suggestion is that multinationals should be treated as a single taxable entity and granted an allowance for equity capital provided by shareholders. The proposal geographically...

The starting points in international taxation, as used by countries around the world to establish and divide tax jurisdiction and as the basis for the charge to tax income, embed an idiosyncrasy of analytic indistinctness. The residence and source principles are geographically geared in the same...

This national report has been prepared as a contribution to the Conference of the European Association of Tax Law Professors entitled ‘Tax Avoidance Revisited: Exploring the Boundaries of Anti-Avoidance Rules in the EU BEPS Context. The conference is to be held in Munich, Germany, on 2-4 June...

Traditionally, countries impose their corporation tax on an entity-by-entity rather than a group-wide basis. As the taxability of entities, tax bases, and tax rates vary from one country to another, these differences give rise to mismatches, leading to double taxation, but also to non-or almost...