International corporate tax system does not succeed very well in taxing the cross-border business of the multinational enterprises. Therefore, both the European Union (EU) and the Organization for Economic Cooperation and Development (OECD) have proposed several tax reforms. We recognize in this...

International corporate tax system does not succeed very well in taxing the cross-border business of the multinational enterprises. Therefore, both the European Union (EU) and the Organization for Economic Cooperation and Development (OECD) have proposed several tax reforms. We recognize in this...

Transnational corporations (TNCs) act as unitary firms in an increasingly globalised economy, but taxes on their profits are levied by national states. Hence, international tax rules have from the start been riven by contradictory approaches: either to determine the taxable profits attributable...

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...

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...

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...

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)...

The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These...

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...

Verlagsinfo: Die Digitalisierung stellt einen technisch-ökonomischen Paradigmenwechsel dar, der sich grundlegend auf die Automobilindustrie als wichtigem Vertreter der traditionellen Wirtschaft auswirkt. In dieser Branche führt die Digitalisierung einerseits zu inkrementellen...

As the OECD and the G20 strengthen their central role in the international tax policy arena, scholars and commentators increasingly question their legitimacy to impose standards and norms worldwide. Calls for greater participation of developing countries led the OECD to introduce the Inclusive...

Ensuring corporate transparency is essential in a globalized economy to prevent tax base erosion and profit shifting (BEPS). This article explains several corporate transparency initiatives by international bodies that are currently spearheaded by the OECD. Under Action 13 of its BEPS Project,...

In the post-BEPS era, China, as a non-OECD member country but a member of the G20, has a positive attitude towards the implementation of the OECD/G20 BEPS Action Plan, especially in the area of treaty abuse and dispute resolution. However, the implementation presents divergence with the OECD/G20...

Multinational enterprises make use of aggressive tax planning strategies because they are able to operate in the legal vacuum that exists between nation states. The tax burden is not mitigated by falsifying the facts of tax-relevant events (as in the case of tax evasion) or through simulation of...

Cross-border intra-group debt represents a significant proportion of total global monetary flows. Responding to tax base erosion from related party interest deductions, countries have introduced domestic rules against "interest stripping" but the heterogeneity of these rules leads to double...

Ein entscheidender Aspekt des BEPS-Projekts von OECD und G20 ist die Bewältigung der steuerlichen Herausforderungen der Digitalisierung der Wirtschaft. Im Oktober 2021 einigten sich über 135 Staaten und Gebiete auf ein bahnbrechendes Konzept zur Überarbeitung wesentlicher Elemente des...

Multilateral Mutual Agreement Procedures (MAPs) and Advance Pricing Arrangements (APAs) offer greater tax certainty to both taxpayers and tax administrations where different parts of the same transaction or arrangement involving a multinational enterprise are covered by multiple bilateral tax...

Schemes of residual profit allocation (RPA) tax multinationals by allocating their 'routine' profits to countries in which their activities take place and sharing their remaining 'residual' profit across countries on some formulaic basis. They have recently and rapidly come to prominence in...

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...

As the OECD and the G20 strengthen their central role in the international tax policy arena, scholars and commentators increasingly question their legitimacy to impose standards and norms worldwide. Calls for greater participation of developing countries led the OECD to introduce the Inclusive...

"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,...

"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...

A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation of the economy. In October 2021, over 135 jurisdictions joined a ground-breaking plan to update key elements of the international tax system which is no longer fit for purpose in a globalised...

This Roadmap provides a follow-up to the 2021 report to the G20 on Developing Countries and the OECD/G20 Inclusive Framework on BEPS. It takes stock of progress since 2021 and sets out key priorities. It also provides a Roadmap to guide actions by interested G20 members and other stakeholders to...

In October 2021, the international community agreed a landmark deal on the two-pillar solution to the tax challenges arising from the digitalisation and the globalisation of the economy. As part of this plan, Pillar Two establishes a global minimum effective corporate tax rate of 15% for large...

The Global Forum on Transparency and Exchange of Information for Tax Purposes is a multilateral framework for tax transparency and information sharing, within which over 160 jurisdictions participate on an equal footing. The Global Forum monitors and peer reviews the implementation of the...