The OECD seeks to align transfer pricing and profit taxation with value creation but fails to provide a clear definition. This paper argues that value creation requires international cooperation and that the profit tax base should therefore be allocated according to standards commonly considered...

Delayed Integration ("DI") is a rule for taxing migrants. It requires that immigrants be taxed in the receiving country only after some period of transition. Conversely, emigrants are released from the obligation to pay home taxes only after a certain period. DI is an alternative to the...

In Europe, the competence for social security and the right to levy income tax lie with the country of employment in cross-border matters. This has two disadvantages. First, the Employment Principle distorts active persons' choice of place of work. Second, the employment-based regulation of...

The usual arguments pro destination-based, consumption-oriented or pro origin-based, production-oriented VAT are found wanting. They largely ignore tax effects on locational choices of firms. This paper provides a comparison of consumption and production taxation within a model of firm and...

The OECD seeks to align transfer pricing and profit taxation with value creation. This article argues that taking this objective seriously requires profit splitting. This is shown by applying Shapley value theory to the problem of allocating a firm's profit tax base to the jurisdictions in which...

Delayed Integration ("DI") is a rule for taxing migrants. It requires that immigrants be taxed in the receiving country only after some period of transition. Conversely, emigrants are released from the obligation to pay home taxes only after a certain period. DI is an alternative to the...