We investigate whether the move from the worldwide tax system to the territorial tax system in Japan in 2009 affects the financial behavior of overseas affiliates of Japanese multinational companies. The reform substantially reduces the tax costs of profit repatriation in the form of dividends...

Based on the agreed Pillar 1 threshold of profitability of 10% (and given that financial and extractive companies are excluded), then only 78 of the world's 500 largest companies will be affected. If the proportion of profit above this threshold liable to Amount A is set to 20% (from the range...

This paper is a draft chapter of a forthcoming book on the taxation of international business profit by the authors of this paper, to be published by Oxford University Press. The group has been meeting regularly for five years, to identify and discuss the key problems of the existing...