The OECD Base Erosion Profit Shifting (BEPS) Initiative as well as the current fairness oriented public discussion regarding the taxation of digital business models highlight the importance and complexity of the arm's length principle. In a theoretical model of an internationally fragmented...

The "fair" taxation of digital business models is challenging. One of the key aspects - both policy makers and the public opinion consider as most pressuring - is the determination of intragroup transfer prices for intangibles used in digital business models. In this paper, we address the issue...

The "fair" taxation of digital business models is challenging. One of the key aspects - both policy makers and the public opinion consider as most pressuring - is the determination of intragroup transfer prices for intangibles used in digital business models. In this paper, we address the issue...

The OECD Base Erosion Profit Shifting (BEPS) Initiative as well as the current fairness oriented public discussion regarding the taxation of digital business models highlight the importance and complexity of the arm’s length principle. In a theoretical model of an internationally fragmented...

The OECD Base Erosion Profit Shifting (BEPS) Initiative as well as the current fairness oriented public discussion regarding the taxation of digital business models highlight the importance and complexity of the arm's length principle. In a theoretical model of an internationally fragmented...

Kunka Petkova und Stefan Greil behandeln einen der zentralen Aspekte von Säule 1 des OECD-Zwei-Säulen-Projekts zur Lösung der steuerlichen Herausforderungen der Digitalisierung, nämlich die Vermeidung der Doppelbesteuerung. Die Autoren stellen verschiedene qualitative und quantitative...

This paper uses micro data from country-by-country reporting of more than 3600 large multinational companies operating in 238 jurisdictions to analyze global profit shifting to avoid taxes. These companies report 7% of their global profits in jurisdictions with effective average tax rates below...

The international tax system faces substantial challenges with respect to taxing profits of multinational enterprises. Policymakers have put the focus on the taxation of the digital economy. The aim of this article is to provide a comprehensive overview over the ALP and the allocation of taxing...

Literature provides evidence of profit shifting of MNEs, particularly by intercompany debt. Therefore, we conducted a broad empirical investigation (survey), focusing on specific issues regarding cross-border intra-group financial transactions. This paper aims to work out empirical evidence of...