The OECD seeks to align transfer pricing and profit taxation with value creation but fails to provide a clear definition. This paper argues that value creation requires international cooperation and that the profit tax base should therefore be allocated according to standards commonly considered...

In 2018, the European Council and the UK and Spanish governments each proposed to introduce a Digital Services Tax (DST), to be levied on the revenue of large digital platforms from advertising, online intermediation, and/or the transmission of data. We offer a rationalization of the DST as a...

The use of digital services is largely non-rival. This paper argues that vanishing marginal costs of supply change policy incentives. Small countries are incentivized to tax the import of digital services. In fact, various countries have already moved towards expanded source taxation of online...

The adequate pricing of intellectual property ("IP") for tax reporting is a largely unsettled issue. Transactional profit-based methods are on the rise although only rated as "methods of last resort" by the OECD. This paper focuses on regulated profit splitting and compares this transfer pricing...

The employment of capital is rival in nature. Small countries do not benefit from taxing its employment. By contrast, the use of digital services is non-rival and small countries do benefit from taxing expenditures on such services. In fact, some countries have already decided to tax digital...

We propose a modified theoretical framework based on John Dunning's classical OLI paradigm in the international business literature to analyze Chinese firms' fast-growing and aggressive outward foreign direct investment (OFDI). In particular, from an institutional perspective, we suggest a...

Against a background of rather mixed evidence about transfer pricing practices in multinational enterprises (MNEs) and varying attitudes on the part of tax authorities, this paper explores how multiple aims in transfer pricing can be pursued across four different transfer pricing regimes. A MNE...

More than 130 countries have accepted the OECD invitation to reform the taxation of multinational enterprises (MNEs). One of two reform pillars aims at granting market countries the right to tax supernormal ("residual") profit without requiring physical nexus. This paper examines the method of...

Firms constantly face new and more stringent tax disclosure requirements and, increasingly, paying a fair share of tax is seen as part of corporate social responsibility. In this paper, we investigate whether mandating qualitative tax disclosure leads to intended outcomes, using, as an exogenous...

Inter-country equity in the taxation of IP is a contentious issue. With its BEPS initiative, the OECD aims at taxing in accordance with value creation even though there are admitted difficulties in determining the actual place of value creation. The European Commission promotes the introduction...