Fundamentals and sources of international tax law -- The jurisdiction to tax -- Source country taxation -- Residence country taxation -- The limited scope of treaties -- Changes of source and residence -- Bilateral administrative issues.

The paper evaluates the effect of Double Taxation Treaties (DTTs) on Spain’s inward and outward Foreign Direct Investment (FDI) for the period 1993–2013. Estimates produce positive and statistically significant coefficients. However, there are some differences between the inbound and...

This paper explores empirically whether and how FDI is affected if multinationals' home countries change taxation of foreign earnings by switching from worldwide to territorial taxation. Our analysis employs data for German inbound FDI based on the ultimate investing country concept. We use a...

Im Mittelpunkt der Arbeit stehen die Auswirkungen steuerlicher Abschreibungen und investitionsfördernder Massnahmen auf die intersektorale und internationale Kapitalallokation. Der Autor analysiert sowohl bestehende steuerliche Vorschriften als auch Reformvorschläge (z.B....

Tax arbitrage is often cited as a potential motive for the substantial growth and complexity of market based finance. Tax treaties are an important feature of the international tax system and can be used to reduce the tax burden on cross-border capital flows. Using an EU firm-level dataset and a...

This paper examines location choices of multinational enterprises (MNEs). We particularly focus on the consequences of double taxation treaties (DTTs) and corporate profit taxes on the probability to choose a location. DTTs have become a key policy instrument used by countries to regulate...

The present paper evaluates the effect of Double Taxation Treaties and the Territorial Tax System of countries on Spain's inward and outward FDI for the period 1993-2013. Estimations produce a positive and statistically significant effect of Treaties for both samples when using a simple binary...

Innerhalb der EG bestehen unterschiedliche Arten von Körperschaftsteuersystemen. Diese unterschiedlichen Systeme bringen Probleme für den innergemeinschaftlichen Kapitalverkehr mit sich. Der vorliegende Beitrag zeigt die wesentlichen Probleme auf und leitet unter Berücksichtigung der...

Tax treaties between countries influence how much tax revenues governments receive from multinational enterprises. These treaties often reduce the withholding tax rates on outgoing dividend and interest payments. We provide illustrative estimates of costs for these two taxes for 14 developing...

Strong evidence shows that the existing pattern of cross-border pension taxation in OECD countries and beyond is extremely diverse and inconsistent, generating a double fairness dilemma for individuals and countries alike. This paper argues that this dilemma cannot be solved within the current...

Out of a total of 2,976 double tax agreements (DTAs), some 60% are signed between a developing and a developed economy. As DTAs shift taxing rights from capital importing to capital exporting countries, the prior would incur a loss. We demonstrate in a theoretical model that in a deal one...

Qualitative case studies suggest that the outcomes of tax treaty negotiations are determined by power politics and negotiating capability. In contrast, quantitative studies have tended to depart from a model that implies absolute gains, full rationality, and perfect information on the part of...

This book contains essays written in honour of Prof. Dr Bertil Wiman, a renowned tax scholar and much-appreciated teacher. Wiman is one of the founding members of EATLP, former chairman of EATLP and former vice president of IFA. The essays cover various topics in the field of international tax...

Double non-taxation stemming from hybrid financial instruments and the solutions provided by the OECD and the European Union for tackling such an outcome are the target of this publication. It focuses on the economic and legal features of debt and equity instruments as well as hybrid financial...

Pension policy reforms across the world in recent decades are a reaction to the changing demographic and socioeconomic environment. While pension scheme redesign has received much attention, the tax treatment of contributions, returns, and benefits of retirement savings remains mostly unattended...

There is a rising share of individuals spending at least some part of their working life abroad and acquiring pension rights. While the portability of pensions and other social benefits has received some analytical attention over the recent decade there is currently limited analytical guidance...

The goal of this paper is to examine the methodology, used by authors Mackie-Mason and Gordon for measuring effects of corporate tax on business organization form, which is connected to issue of double taxation, in the United States and find out, if the same approach can be applied on business...

Reforming the Corporate Tax in a Changing World contains the six major papers presented at a symposium co-sponsored by the Canadian Tax Foundation and the University of Calgary's School of Public Policy, with an introduction by Bev Dahlby. The volume updates the analysis of coporate income tax...

Introduction -- Core International Tax Policy and Law -- Evasion and Avoidance According to the BRICS -- Countering Avoidance : SAARs -- Information Exchange -- Countering Treaty Benefits -- BEPS Final 2015 Reports -- Dispute Resolution -- BRICS and FDI : DTC Anti-abuse and Dispute Resolution --...

This book provides an overview of the taxation of income from services under double taxation conventions (DTCs) in major jurisdictions across the world. Especially due to the precipitous growth of the digital economy and thus the increased internationalization of services provisions, the...

This volume of the Cahiers has been published by Sdu, The Netherlands, on behalf of the International Fiscal Association (IFA). Once a year the Cahiers de Droit Fiscal International are published and distributed free to all the members of the Association.00These Cahiers contain a wealth of...