Transnational corporations (TNCs) act as unitary firms in an increasingly globalised economy, but taxes on their profits are levied by national states. Hence, international tax rules have from the start been riven by contradictory approaches: either to determine the taxable profits attributable...

Cross-border intra-group debt represents a significant proportion of total global monetary flows. Responding to tax base erosion from related party interest deductions, countries have introduced domestic rules against "interest stripping" but the heterogeneity of these rules leads to double...