The paper evaluates the working of German CFC rules that restrict the use of foreign subsidiaries located in low-tax countries to shelter passive investment income from home taxation. While passive investments make up a significant fraction of German outbound FDI, we find that German CFC rules...

In den letzten Jahren lässt sich im Zuge der Erweiterung der Europäischen Union in verstärktem Maße eine Zunahme deutscher Investitionen in Polen feststellen. Diese werfen die Frage nach dem Einsatz steuerlich günstiger Investitionsvehikel und Finanzierungsarten auf. Dabei gewinnt neben den...

The rapid diffusion of the internet and electronic commerce changes the way business and international trade take place. The new economy poses new challenges to the international regulatory framework, since small distortions due to differing sets of regulations and taxation between countries...

The paper provides a framework for designing international tax rules by outlining the various behavioral margins they apply to. It then goes on to analyze three specific policy issues in terms of preserving the neutrality of choices along the relevant margins: (1) Which foreign taxes should be...

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...

In this paper, an outline of the consequences of the increased use of ICT on international corporate taxation, namely on the tax attributes and the scope of taxation, is given. It is argued that the concept of capital export neutrality shall prevail, as it is deemed to be the most appropriate to...

Trade relations are governed by the multilateral GATT, whereas the avoidance of international double taxation rests on a network of around 2000 bilateral treaties. Given the two regimes' similar economic rationales this difference between bilateralism in international double tax avoidance and...

This paper investigates the consequences of a series of alternative international tax designs on the strategy of a multinational enterprise regarding the cross border distribution of its investment and the choice of its financing behavior. We start with a world where no international tax rules...