The paper investigates the role of holding companies and conduit entities in German inbound and outbound FDI. It identifies the relevant conduit countries that act as stepping stones. Several tax and non-tax factors for the set-up of indirect structures are empirically identified. Withholding...

The European Commission proposed to provide multinational companies with a Common Consolidated Corporate Tax Base (CCCTB) for their EU wide activities. The main goal of this proposal is the removal of existing tax obstacles to cross-border economic activity which are mainly caused by the...

The U.S. international income tax rules, which govern the U.S. tax treatment of multinational companies, employ five key concepts: corporate residence, source of income, foreign tax credits with limits, deferral, and subpart F. This paper, which is a draft version of chapter 2 of a book in...