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...

How countries tax the profits of multinational enterprises has become hopelessly outdated. The recent OECD/G20 Base Erosion and Profit Shifting Project has left the existing international corporate taxation framework essentially intact. Perhaps it is time to consider a truly fundamental reform...

This paper addresses the recent developments surrounding the political agreement reached on 8 October 2021 within the Inclusive Framework on Base Erosion and Profit Shifting on a reform of the international business taxation framework under the heading ‘Addressing the tax challenges arising...

The paper comments on the contribution in this edition entitled 'Unilateral Digital Services Tax in Africa; Legislative Challenges and Opportunities' upon an invitation by the Intertax editorial board. The current paper also serves as an independent reflection on contemporary developments in...

The international corporate income and capital gains tax (CGT) systems of basically all modern nation states share a common objective. All seek to effectively ‘capture' multinational enterprises (‘MNEs') that are economically present within the respective taxing state's geographical borders...