This paper aims to present the second phase in developing the discourse on international taxation, characterised by the fight against harmful tax competition. The premise is that this discourse results from the OECD’s consolidation as the technical forum for developing the international tax...

The international tax framework involves the interaction of domestic laws and international tax treaty obligations. The major concern faced by this framework is the distribution of the right to tax a particular country. Multi-national enterprises use different tax planning techniques to take...

A Theory of International Taxation combines qualitative and quantitative analyses to shed light on the shaping of the international tax regime (ITR) over the last century. It offers a theory of the ITR as the product of the strategic interaction between three small groups: international...

This study investigates the impact of residence country’s double tax relief method and of tax sparing agreements, on the difference between developing countries’ withholding taxes under domestic law, and negotiated withholding taxes in tax treaties with OECD member states. Using a dyadic...

In 2021, the OECD proposed new rules for the cross-border taxation of multinational corporations. The proposed rules set forth the most significant reform to international tax rules in several decades. They follow approximately a decade of multilateral negotiation led by the OECD and drafted by...

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...

This paper reconsiders the empirical evidence of the relationship between tax treaties and FDI using U.S. outbound FDI to 78 countries over the period of 2007-2018. Unlike previous studies, we explicitly consider differences in the tax environments of recipient economies, including their...