We examine the effect of compliance frictions in reclaiming foreign withholding taxes on Foreign Portfolio Investments (FPI) using a comprehensive panel of FPI stocks of 83 countries, including EU Member States, between 2005 and 2019 and country-pair-specific withholding tax rates. We find a...

This paper articulates and, using newly-assembled data, explores how international taxation affects aggregate tangible cross-border investment. Spillovers from statutory tax rates abroad seem: As sizable as effects from the host's rate; larger than previous consensus values (attributed to a...

This article discusses three positive elements of the American Jobs Creation Act. First, the Act contains the most far-reaching simplification of the US international tax regime in many decades. Specifically, the Act finally (after many failed attempts over the course of the last two decades)...

On 5th October 2015, the OECD along with G20 finally released a fifteen-point action plan on their project on Base Erosion and Profit Shifting (BEPS). Issues related to transfer pricing formed a major part of this final report, with BEPS Action Plan 8-10 focusing on it exclusively. The actions...

The past decade has witnessed the creation of a new international tax regime (ITR). The original ITR was created a century ago by the League of Nations. Until the 1980s, it functioned reasonably well, and prevented most instances of double taxation and double non-taxation by allocating...

Will implementing the UN FACTI Panel’s principle-based approach as part of the formulation of taxing and profit allocation rules under the OECD BEPS’ policy driven approach give these rules the legitimacy needed for equitable and fair enforcement?

This paper aims to offer a theory of global tax hubs, bringing fresh light on their strategic role in the international tax regime (ITR) during half a century (the 1960s through the 2000s). It focuses on non-G20 tax hubs as a case study. Specifically, the paper addresses two questions that have...

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...

Friedrich Hayek’s 1944 book, The Road to Serfdom, warned of the dangers to a free society from central planning. Efforts by the rich country clubs of the Organization for Economic Cooperation and Development (OECD) and European Union (EU) to impose new international tax rules through a variety...