Die OECD hat mit ihren Reformvorschlägen zum Zwei-Säulen-Modell für eine neue, vermeintlich gerechtere globale Steuerordnung große Erwartungen geweckt. Ambitioniert sind Zeitplan und Ziele. Noch 2022 soll die gesetzgeberische Umsetzung der Regeln erfolgen, die das internationale Steuerrecht...

Anfang 2021 hat die Europäische Kommission den formalen Prozess zur Entwicklung eines stabilen regulatorischen und steuerlichen Rahmens zur Bewältigung der Herausforderungen der digitalen Wirtschaft wieder aufgenommen. Bereits 2018 wollte die Europäische Kommission eine politische Einigung...

As of the beginning of 2021, the European Commission has restarted the formal process to develop a stable regulatory and tax framework to address the challenges of the digital economy. In 2018, the European Commission initially intended to gain political agreement on a Digital Services Tax (DST)...

Based on the agreed Pillar 1 threshold of profitability of 10% (and given that financial and extractive companies are excluded), then only 78 of the world’s 500 largest companies will be affected. If the proportion of profit above this threshold liable to Amount A is set to 20% (from the...

This article addresses the interaction between the Global minimum tax rules (namely, the Income Inclusion and the Undertaxed Payment Rule) with tax treaties. In particular, the article analyses potential limitations to the application of the Income Inclusion Rule by the provisions of Article 9...

The integration of world capital markets carries important implications for the design and impact of tax policies. This paper evaluates research findings on international taxation, drawing attention to connections and inconsistencies between theoretical and empirical observations. Diamond and...

Corporate tax laws vary significantly between different jurisdictions. Over the past four decades, governments globally competed for business activity by lowering statutory and effective corporate tax rates. Many governments provide special tax incentives for businesses to invest and expand...

The article presents the procedure of concluding an advance pricing agreement between the taxpayer and the tax authority as a tool of tax strategy of large international groups. It was pointed out that the advance pricing agreement may be a key tool to protect affiliates operating in different...

"Robertson and Tyrala provide a theoretical and empirical analysis of emerging markets and the offshore economic system. Few analysts are aware that corporate structures formed in Mauritius hold over $700 billion in assets in the global economy. In the last decade, taxation has become a central...

"Wealth exists only for the benefit of mankind. It cannot be measured adequately in yards or in tons, nor as equivalent as so many ounces of gold; its true measure lies only in the contribution it makes to human well-being. Now, when bricks and sand and lime and wood are built up into a house,...

Fundamentals of the Taxation of Permanent Establishments -- The Attribution of Profits to Permanent Establishments -- Digitalisation of the Economy and Its Implications for the PE Concept -- Adapting the International Corporate Tax System to the Digitalisation of the Economy.

"International taxation rules allow Apple, Starbucks, and Nike to avoid billions of dollars of taxes. News stories have focused on tax dodging in developed countries, but developing countries lose at least $200 billion per year in tax revenue. In the Global South, an international tax regime...

This chapter examines three areas where multilateral cooperation is necessary: climate change, international corporate taxation, and sustainable development. Progress in addressing challenges in all these three areas through global cooperation is crucial. We need to find effective ways to limit...

This book examines existing mineral fiscal policies covering income taxation, royalties, free carried and participative (community and government) interests and also highlights the impacts of these policies on the feasibility of mineral projects as well as on revenue and other benefits to the...

We show that corporate taxation systems regarding foreign dividends and capital gains across 49 countries differ in many aspects, contradicting the requirements for capital ownership neutrality and indicating that ownership patterns are distorted. Consequently, a national tax policy maker may...