M&A play a major role in the materialization of globalization, but it is just one of several challenges that globalization poses to international tax policy, all of which share two basic tensions that may have been present in the past, but have been significantly exacerbated in importance by...

Unprecedented attention to aggressive international tax planning has shaken the earth under the most powerful players in the world of international tax policy design. The media exposure of what Bloomberg’s calls “The Great Corporate Tax Dodge,” combined with the ever-growing discontent of...

Unprecedented attention to aggressive international tax planning has shaken the earth under the most powerful players in the world of international tax policy design. The media exposure of what Bloomberg's calls “The Great Corporate Tax Dodge,” combined with the ever-growing discontent of...

The article argues that the BEPS project has made only minimal progress in its work on the transfer pricing for intangibles, despite the prominence of the issue. More specifically, it achieved none but increased confusion and incoherence in the context of the specific rules for CCAs