In recent years, there is a growing tendency in international taxation to move the right to tax the corporate income of multinational enterprises to the jurisdiction where their customer base is located. One widely discussed proposal applies a sales-only formula to group-wide profits of...

A number of regional trade agreements (RTAs) include investment protection provisions that may limit a country’s ability to change tax measures. This limitation could raise concerns for States as regards the recently agreed global minimum tax under the Global Anti-Base Erosion (GloBE) Rules,...

The G-7 countries’ recent accord on a global minimum corporate tax has been proclaimed a breakthrough in international tax cooperation: at the least, it is expected to spur international tax negotiations at unprecedented scales. Yet these developments seriously challenge our understanding of...

It contains a summary of disputes concerning income tax measures that have arisen at the WTO since its establishment, with special attention to the protracted dispute between the EC and the US over the latter's FSC/ETI schemes.

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...

The OECD recently emerged as the site of unprecedented, multilateral, and seemingly high-stakes negotiations about the future of international business income taxation. Judging by the political resources deployed in these negotiations, international tax has entered unchartered territory....

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...

Increasingly linked by regional and global ties, national economies depend more than ever on international investments and trade. While trade and investment have become international, however, taxation has remained national, preserving and strengthening one of the few remaining barriers to...

A creative and useful solution for teaching multi-jurisdictional taxation was found and successfully implemented. The revised course pedagogy better meets the needs of a student body with wide-ranging differences in prior business experience and preparation for the course when the 150-hour...