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...

Using unique tax audit data of 499 German firms, we analyze whether family firms, public firms, financially constrained firms, and those firms with managers with low tax morale substitute two tax strategies, book-tax conforming and nonconforming tax avoidance strategies, and examine the effect...

This paper reveals how tax complexity, in the form of loopholes and assets overlapping different sections of tax returns, contributes to tax avoidance and evasion. Using administrative data from the Netherlands, it shows how an auditing announcement in 2005 triggered large increases in declared...

We examine the extent to which European listed firms use deferred tax accounting to manage their GAAP earnings in order to meet financial analysts’ earnings forecasts. The cross-country nature of our data allows us to compare the use of this earnings management channel across countries and to...

The objective of this study is to show that an indirect interest in a controlled foreign corporation (CFC) through hybrid participation instruments may not be subject to CFC taxation. This is the case where the taxpayer holds a hybrid participation instrument in a foreign intermediary company...

Estonia’s tax mix has been traditionally reliant on consumption taxes—especially VAT—whereas income taxes are a relatively small share of revenue. Recent and expected changes will further shift the tax burden in this direction. Consumption taxes are less distortive than income taxes, but...

Source-based taxation and the arm’s length standard have been foundational elements of the international tax system for many decades. With the advent of the highly digitalized platform firm, the OECD and many other stakeholders assert that these principles have been rendered obsolete. In their...

The study aims to evaluate the country's legal framework for taxing digital transactions. Specifically, the extent to which the provisions of the law can map onto the value of digital markets. Based on the findings on the structure of the digital commerce value chain, and its possible...

Domestic resource mobilization is essential for developing countries to achieve the Sustainable Development Goals by the deadline of 2030. Concomitantly, Illicit Financial Flows (IFFs), which also lead to asset theft, are major means through which these countries are losing resources. This...

The taxation of the digitalized economy is the single most important topic in international tax negotiations today. The OECD has devised a "Two Pillar solution" to the problem. Pillar One is focusing on a reallocation of taxing rights to market jurisdictions, which are largely expected to be...

In this research paper, we attempt to estimate the tax revenues to be gained (or lost) by the South Centre and African Union's Member States under the Amount A and Article 12B regimes. Our analysis relied on sources of information available to private sector researchers but did not involve...

The proposed OECD Pillar One and Two reforms mark a significant shift in the way large multinational enterprises are taxed on their global incomes. However, while considering the reform at the proposed scale tax administrators must be able to compare the revenue gains with alternatives. This...

The Research Paper commences with an overview of Pillar One and Pillar Two followed by detailed discussions on salient provisions of Pillar Two. Pillar Two is envisaged to have a widespread impact on Small Island Developing States (SIDS) which are a distinct group of 38 United Nations (UN)...

This paper aims to describe the state of multilateral and unilateral efforts to tax digital services; summarize the state of economic analysis on digital services taxes; and provide an overview of where the Philippines stands in relation to other countries in digital service taxation. On-going...

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...

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...

Weisen allgemeine Antimissbrauchsvorschriften verschiedener Steuersysteme trotz unterschiedlicher Ausgestaltung mehr Ähnlichkeiten auf als es zunächst scheint? Um diese Frage zu beantworten, befasst sich die Autorin in ihrer Arbeit mit dem Recht Hongkongs, Singapurs und der Volksrepublik China...

This research investigates the impact of tax justice perception and tax understanding on the compliance of Small and Medium-sized Enterprises (SMEs) with government regulation Number 55, 2022, in Surabaya. The study, conducted at KPP Pratama Surabaya Wonocolo employs a quantitative approach,...

In einer Zeit rasant fortschreitender digitaler Transformation spielt Künstliche Intelligenz (KI) eine zunehmend zentrale Rolle in verschiedensten Bereichen unserer Gesellschaft. Diese Schrift widmet sich speziell der Bedeutung und den Auswirkungen der KI im Steuerrecht. Wie kaum ein anderer...

The main goal of this study is to assess whether, and if so, how the tax policy is implemented in Poland in relation to informal partnerships. The justification for conducting research in this area is the growing number of such relationships and the demands formulated by the public on the...