This paper studies how the global minimum tax shapes national tax policies and welfare in a formal model of international tax competition with heterogeneous countries. The net welfare effect is generally ambiguous from the perspective of non-havens. On the one hand, the global minimum tax raises...

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 range...

With multinational enterprises (MNEs) centralizing production facilities, market countries claim not to receive their fair share of taxes. A reform of international business taxation that includes new profit allocation rules as well as the introduction of minimum taxation is being considered as...

The paper aims to identify the significant tax barriers to foreign direct investment (FDI) in Poland, in particular in the form of a permanent establishment (PE), in the context of new developments in international tax law. Due to the recommendations of the Base Erosion and Profit Shifting...

According to plans put forward by the OECD/G20 Inclusive Framework on BEPS, a share of residual profit earned by eligible MNEs is to be taxed by market jurisdictions. For this purpose, revenue-based formulaic apportionment of residual profit is proposed. This note argues against the use of a...

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...

We study the choice between source-based and destination-based corporate taxes in a two-country model, allowing multinational firms to use transfer pricing to allocate profits across tax jurisdictions. We show that source-based taxation is a Nash equilibrium for tax revenue maximizing...

We investigate how changes in firm productivity after M&As are affected by differences in profit taxation between the target and the acquirer. We argue that tax differentials distort the efficient allocation of productive factors following an M&A and thus inhibit the realization of productivity...

As part of its action plan against base erosion and profit shifting (BEPS), the OECD (2015) has proposed six indicators to measure profit shifting activity. These indicators add to past and ongoing efforts in academic tax research to empirically identify the scale and tax sensitivity of...

In its 2015 Final Report on “Measuring and Monitoring BEPS, Action 11”, the OECD introduced six indicators to quantify and evaluate base erosion and profit shifting (BEPS) activity over time. In this study, we revisit three selected indicators, provide a numerical update for recent periods...

Under Action 14, countries have committed to implement a minimum standard to strengthen the effectiveness and efficiency of the mutual agreement procedure (MAP). The MAP is included in Article 25 of the OECD Model Tax Convention and commits countries to endeavour to resolve disputes related to...

The issues and challenges in taxation in the digital economy stem from the complex and multifaceted nature of the digital economy. Reaching a common understanding and measurement of its size and impact is critical in devising a tax regime for the digital economy. In APEC Secretariat (2019), the...

The aim of the paper is to highlight, at a theoretical level, the effects of globalization on fiscal policy, as well as the issue of profit shifting at OECD level, given that, although substantial progress has been made internationally in multilateral fiscal coordination, it remains at a...

Steuerrecht ist nationales Recht. Somit kann jede einzelne Nation über steuerrechtliche Regelungen Forschung und Entwicklung fördern und gegebenenfalls Besteuerungssubstrat aus anderen Ländern absaugen. Eine dieser speziellen Regelungen ist die Patentbox Bei der vorliegenden Arbeit handelt es...

Tax treaties are often seen as a means to mitigate fierce tax competition. We challenge this view by arguing that taxes on passive income reduce e↵ective average tax rates, and induce neighbouring countries to react by reducing bilateral tax rates. As opposed to traditional tax competition,...

Steuerrecht ist nationales Recht. Somit kann jede einzelne Nation über steuerrechtliche Regelungen Forschung und Entwicklung fördern und gegebenenfalls Besteuerungssubstrat aus anderen Ländern absaugen. Eine dieser speziellen Regelungen ist die Patentbox Bei der vorliegenden Arbeit handelt es...

Upon more than 400 judgements on direct taxation, the case law of the European Court of Justice has considerably shaped Member States' tax systems. Based on Member States' tax law adjustments in the context of four landmark rulings on corporate income taxation, we analyse whether case law is a...

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...

El mundo enfrenta un panorama de alta incertidumbre durante el 2020 como resultado de la pandemia del coronavirus y sus efectos sobre la población y la economía global. La propagación del COVID-19, aparte de su impacto sobre la población y la salud pública, condujo en todo el mundo a...

The research revolves around the topic of offshore destinations and role of tax in the decision where to locate TNCs’ investments or relocate employees. This paper exploits rich country-by-country reporting (CbCR) data that banking institutions operating in the EU with annual turnover over 750...

Technology and digitalization are transforming economic activity, but tax policies are lagging behind. The development also encompasses a broad shift in value-creation, with less emphasis on physical production and more on soft knowledge/intangibles, notably copyrights, firm-specific processes,...

In the contemporary age of global capitalism, international taxation - the taxation of income earned from cross-border economic activity - has become a high-stakes issue. International taxation touches upon the foundations of modern society as an arena for struggle between nation-states and...

Die fortschreitende Digitalisierung führt zu neuen Formen der Wertschöpfung. Dies stellt das bestehende System der globalen Unternehmensbesteuerung vor große Herausforderungen. Die OECD diskutiert jedoch derzeit nicht über eine gezielte Anpassung dieses Systems, sondern schlägt eine...

In this context, Bhutan can become wealthier through accelerating both domestic and foreign investment, as well as signing investment treaties. These investments could provide not just capital but also bring necessary skills, knowledge and ideas, and help the country move beyond hydropower....

Recent efforts to reduce international tax evasion focus on information exchange with tax havens. Using bilateral bank data for 1,397 country pairs in a balanced quarterly panel from 2003:I – 2017:IV, we first show that information-on-request treaties with tax havens reduce bank deposits in...