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This paper evaluates the Multilateral Convention to implement Pillar I Amount A, released by the OECD in October 2023, and the alternative proposal of Art. 12B for tax treaties suggested by the UN, with a particular emphasis on the perspective of developing countries. We conduct a comparative...
Persistent link: https://www.econbiz.de/10014518661
The Tax Cuts and Jobs Act constitutes the largest change to the US tax system since the 1980s and thoroughly alters the way in which multinational companies are taxed. Current assessments on the reform’s international impact vary widely. This article sheds light on the tax reform’s expected...
Persistent link: https://www.econbiz.de/10012892092
neutrality analysis, this article argues that residence-based taxation has, at best, no advantages over source-based taxation in …, simultaneously with the other tax neutrality theories, simply by source-based taxation (not necessarily with globally harmonized …
Persistent link: https://www.econbiz.de/10013083816
Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in selective federal states to evaluate the economic properties of formula apportionment relative...
Persistent link: https://www.econbiz.de/10012859856
vertical company structure, I provide evidence of a horizontal driver: once a form of group taxation is available, groups seem …
Persistent link: https://www.econbiz.de/10013101102
vertical company structure, I provide evidence of a horizontal driver: once a form of group taxation is available, groups seem … to spread their national investments across more subsidiaries. -- Corporate Taxation ; Foreign Direct Investment …
Persistent link: https://www.econbiz.de/10009657618
-location-based profit taxation (Pillar 1) and a global minimum tax rate of 15% (Pillar 2). Using high-frequency asset price movements around …
Persistent link: https://www.econbiz.de/10013297506
phase. World financial environment had remained depressed since 2008. The actions of the government in the area of taxation … to law further aggravated the taxation environment specially in the area of international taxation. This badly affected … deals with the concerns of the multinationals in the area of taxation environment. Section two deals with the genesis of the …
Persistent link: https://www.econbiz.de/10011489954
that would be much better served by a new taxation system that would truly put the taxation of foreign income on par with … the taxation of domestic income. In addition to achieving a number of important tax policy objectives, this system would …
Persistent link: https://www.econbiz.de/10013059774
-country taxation on its worldwide earnings, a multinational cannot achieve double nontaxation. That will eliminate or significantly …
Persistent link: https://www.econbiz.de/10013064383