If conventional instruments of strategic trade policy are unavailable, the system of foreign profit taxation and transfer price guidelines may serve as surrogate policy instruments. In this paper, I consider a model where firms from two countries compete with each other on a third market. I...

Kürzlich hat die Verfasserin ihre Dissertation mit dem Titel „Geschäfte mit Nahestehenden: Eine grundsätzliche Lösung für das Außensteuer-, Handels- und Gesellschaftsrecht - Unter besonderer Berücksichtigung von BEPS Bericht 8 und des Wettbewerbsrechts“ veröffentlicht. Aufgrund der...

Soft law plays an important role in the regulation of international tax matters. This paper focuses on the case of the OECD Transfer Pricing Guidelines and analyses the relationship between this non-binding instrument and the formal sources of law. From the perspective of international law, the...

We analyse tax competition with corporate profit taxes in a common market where tax revenues are allocated according to an apportionment formula. As a general rule, tax competition is sharper the higher is the tax elasticity of the apportionment formula which, in turn, depends on the properties...

This paper investigates the transfer pricing risk awareness of multinational firms using cross-sectional data of more than 350 firms located in 24 countries and classified in 12 industries. Moving beyond the sole tax optimization motives of multinational firms, we extend the existing literature...

This paper presents suggestive evidence of income shifting in response to differences in corporate tax rates for a large selection of OECD countries. We use a new method to disentangle the income shifting effects from the effects of tax rates on real activity. Our baseline estimates suggest that...

Ireland’s low corporation tax regime has proved especially attractive to foreign multinational companies operating in high-tech sectors. Ireland’s increasing concentration in such sectors has facilitated the country’s rise in the international R&D rankings. On a sector by sector basis...

This article analyzes profit taxation according to the arm's length principle in a new model where heterogeneous firms sort into foreign outsourcing. We show that multinational firms are able to shift profits abroad even if they fully comply with the tax code. This is because, in equilibrium,...

Many studies have shown that the activities of multinational corporations are quite sensitive to differences in income tax rates across countries. In this paper I explore the interaction between multinational taxation and abatement activities under an international emissions permit trading...