Analysis of the international network of double tax treaties reveals a large potential for tax avoidance. Developing countries are, on average, not more likely to suffer from tax revenue losses than other countries. Yet, this average masks the fact that several countries, such as Bangladesh,...

Taxation of cross-border services has been identified as a high priority issue in the United Nations (UN) negotiations to establish a new global framework for tax. This paper analyses the defects of international tax rules as applied to services, and their exploitation by multinational...

In this paper, we attempt to estimate the tax revenues to be gained by the Member States of ATAF, WATAF, AU and the South Centre under the Amount A and an alternative stylized DST taxation regime. Our research demonstrates that the comparative revenue effects of the Amount A and DST taxation...

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS), known as the Multilateral Instrument (MLI), is an innovative multilateral method for the modification of bilateral tax treaties (BTTs). The MLI has transposed part of the...

Bilateral tax treaties are an integral part of the international tax system. Despite this, the accounting literature on tax treaties is almost non-existent, with the majority of the research being done in the public finance and tax law research fields. The goal of this paper is to spur an...

This policy brief reflects on an underexplored proposition: that bilateral tax treaties – particularly treaties involving (middle- and) low-income countries – should contain an expiration or sunset clause. The brief examines some reasons why it may be sensible for a low-income country to...

Prior studies show that taxes matter for the residential locations of high-income earners. But, states raise a significant share of revenue from nonresidents. Using variation in state tax rates, we provide causal evidence on the effect of the net-of-tax rate on the location of labor supply for...

Dividend taxation in India has undergone several changes. India levied the highly contentious dividend distribution tax (DDT) for over two decades. This contribution pertains to a ruling in Giesecke & Devrient [India] Pvt Ltd. v. The Additional Commissioner of Income tax from the Indian Income...

Intellectual Property (IP) assets enjoy a unique advantage in tax planning. Owing to their intangible nature and lack of physical substance, IP assets can be methodically parked to transfer income between tax jurisdictions. In 2016, the Delhi High Court was presented with a dispute in which IP...

Given the Republican-controlled House and narrow Democratic majority in the Senate, the Biden Administration has found itself in the perilous situation of needing to raise tax revenue while retaining the support of moderate Democrats. President Biden has proposed raising revenue by bringing the...

Drawing on narrative analysis developed by communications scholars, and applied by scholars of economics and international law and in policy analysis, this article studies action 1 of the Organisation for Economic Co-operation and Development’s (OECD’s) base erosion and profit shifting...

Developing countries around the world are facing challenges funding necessary public services such as health, education, and climate change adaptation due to a lack of revenue. Double tax treaties, which predominantly favor the allocation of taxing rights to the residence jurisdiction in...

International tax coordination has reached impressive results after the turn of the century. Multi-lateral agreements like the Common Reporting Standard or the BEPS Action Plan are clear signs of the willingness of a large number of states to cooperate in fiscal matters at a global scale....

Double taxation treaties, by assigning taxing rights to rival countries and thereby eradicating double taxation, aim to facilitate cross-border trade and investment. The eradication of double taxation is achieved through reductions in withholding tax rates on passive income in source countries,...

Shifting intellectual property (IP) rights across jurisdictions is a well-known strategy of multinationals to reduce corporate income taxation. We investigate the extent to which the flows of remunerations for the use of IP rights are affected by differences in corporate income and withholding...

The 2017 US tax legislation - widely referred to as the Tax Cut and Jobs Act (TCJA) - fundamentally transformed the US system of international taxation. It ostensibly ended worldwide taxation but introduced, for instance, a new tax on "Global Intangible Low-Taxed Income" (GILTI). This paper...

Purpose - For many global firms and corporate oligopolies, transfer pricing is essential. The transfer pricing literature as it is currently written is succinctly summarized in this study. The authors offer a thorough analysis of transfer pricing research in this study. This review sheds light...

This Note considered whether a state can tax the worldwide combined income of a unitary business of a United States parent corporation and foreign subsidiaries. The primary alternative to worldwide combined reporting is the federal government's arm's length method of taxing foreign source...

Reaching a common understanding of the interpretation and enforcement of tax treaties is a desirable policy goal. It results in higher certainty and helps to increase their effectiveness thus enhancing all the purported objectives of these international agreements. In this regard, dispute...

Escape clauses, where small firms are exempt from particular tax rules, is a crucial feature of a number of corporate tax schemes, but creates incentives to avoid taxation by manipulating the measures that determine inclusion. We evaluate the impact of thin capitalization rules, which commonly...

Escape clauses, where small firms are exempt from particular tax rules, is a crucial feature of a number of corporate tax schemes, but creates incentives to avoid taxation by manipulating the measures that determine inclusion. We evaluate the impact of thin capitalization rules, which commonly...

Countries wishing to reform their tax system must consider that their proposals are in line with both international trade law and international tax law, which, if on the one side, are two different branches of international law, on the other side, they share overlapping elements in relation to...

In this article the author seeks to establish a functioning non-context specific definition of an “Unequal Treaty” which takes into account underlying principles of state equality, the concept of treaties and non-coercion whilst sitting outside any single historical moment, by reference to...

UN Resolution 77/244, adopted by the General Assembly on 30 December 2022, reaffirms earlier commitments by the United Nations to improve international tax cooperation, fight illicit financial flows, and combat aggressive tax avoidance and evasion. The resolution asks that the Secretary-General...

This study investigates the impact of residence country’s double tax relief method and of tax sparing agreements, on the difference between developing countries’ withholding taxes under domestic law, and negotiated withholding taxes in tax treaties with OECD member states. Using a dyadic...

This short note sets out select preliminary observations on the imposition of the tax liability and elimination of double taxation under the OECD Secretariat's Progress Report on Amount A of Pillar One.It includes a step-by-step process guide to identifying the 'relieving jurisdiction' in order...