"Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the...

This article aims to offer the first structural analysis of tax disputes under institutional instability using a core element of the international tax regime as an example. It offers a theory grounded on Mancur Olson's seminal contribution to group dynamics, the logic of collective action. It...

This chapter offers the first global taxonomy of treaty dispute patterns emerging in the almost first 100 years of the international tax regime (ITR). The time and space dimensions of the taxonomy are as follows. The time dimension covers the era which ran from 1923 — when four economists...

This chapter shows the evolutionary path of transfer pricing dispute resolution in twenty countries from the five continents since 1799. It consists of six core stages that encapsulate how the ALP has gradually evolved from being a rule-based regulation to a procedural, standard-based regulation...

This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and...

The way in which the countries studied here solve tax treaty disputes is normally related to exogenous elements. Local endowment of natural resources is a neat example. This can be seen as a continuum. On one end, countries with large endowments of natural resources, such as Argentina, Brazil...

This chapter offers the first global quantitative analysis of tax treaty disputes emerging in the almost first 100 years of the international tax regime (ITR). The time and space dimensions of the analysis are as follows. The time dimension covers the era that ran from 1923 — when four...

The allocation norm regarding the profits of associated enterprises, now encapsulated in Article 9 of the OECD and UN Model Conventions, is engaged in a creeping, spiral evolution since the beginning of the 20th century: from standards to rules, and then back to standards. The spiral trajectory...

This paper aims to offer a theory of global tax hubs, bringing fresh light on their strategic role in the international tax regime (ITR) during half a century (the 1960s through the 2000s). It focuses on non-G20 tax hubs as a case study. Specifically, the paper addresses two questions that have...

The global economy's centre of gravity is shifting. Emerging and developing countries have been contributing over 50% of the global GDP since the onset of the 21st century, which is unprecedented since the Industrial Revolution. This article offers the first analysis of the creeping convergence...