Luxembourg receives ample investment from multinational corporations, in part due to some attractive features in its international tax rules. Around 95 percent of these foreign investments pass through Luxembourg via companies performing holding and/or intra-group financing activities. While...

This study aims to provide feedback to the OECD on its Public Consultation, launched on 8 November 2019, on the specific matters of the Global Anti-Base Erosion (GloBE) Proposal, also known as Pillar Two of the BEPS 2.0 Project, as included in the Public Consultation Document (The "Public...

This paper discusses the implications for tax systems of globalization of capital markets and of economies. It shows the extent to which particular taxes are affected by the globalization process. It speculates on future developments in this area and on tax competition

The OECD Programme of Work on the tax challenges arising from the digitalization of the economy comprises a so-called GloBE (Global Base Erosion) or Pillar Two proposal, consisting of a series of measures aimed at establishing a floor to tax competition by achieving minimum taxation of the...

This study was drafted as the EU topical report for IFA's general report on the topic reconstructing the treaty network and deals with the intersection of three areas: i) European Union law; ii) the OECD's Base Erosion and Profit Shifting project (BEPS) and its implementation, and; iii) member...

We have several kinds of measures for mitigating or eliminating international double taxation and stimulating international trade. Some of them are unilateral, the others are bilateral, and still others are multilateral. A natural question here: why we have all these measures? The answer lies in...

This paper uses recent data on a large cross-section of countries to study the determinants of corrupt activity. The main contribution is to examine the effects of different types and severities of government regulations on corrupt activities. The results show that greater prosperity and...

We examine shifts in British income inequality and their causes between 1911 and 1949. Newly re-discovered Inland Revenue 1911 estimates and more detailed data from subsequent official income distribution enquiries are used to show that income was substantially more concentrated at the top of...

The existing double taxation agreement between the United Kingdom of Great Britain and Northern Ireland and the Polish People's Republic (signed back in 1976 amidst a political and economic détente promoted by the relatively liberal and progressive – on a COMECON scale – communist...

Can a WTO Member discriminate against foreign suppliers of services located in jurisdictions that refuse to share information with a government to permit it to determine if its nationals engage in tax evasion? Does it matter if the Member uses standards developed by an international body as the...