Globalization tends to open new era of transnational Corporation, where the determination of tax bases has become very technical. Tax can either be imposed on the basis of incorporation of accompany or on the basis of the income that can be attributed to a particular territory. The three main...

Introduction -- Core International Tax Policy and Law -- Evasion and Avoidance According to the BRICS -- Countering Avoidance : SAARs -- Information Exchange -- Countering Treaty Benefits -- BEPS Final 2015 Reports -- Dispute Resolution -- BRICS and FDI : DTC Anti-abuse and Dispute Resolution --...

This paper explores empirically whether and how FDI is affected if multinationals' home countries change taxation of foreign earnings by switching from worldwide to territorial taxation. Our analysis employs data for German inbound FDI based on the ultimate investing country concept. We use a...

The taxation of the digitalized economy is the single most important topic in international tax negotiations today. The OECD has devised a "Two Pillar solution" to the problem. Pillar One is focusing on a reallocation of taxing rights to market jurisdictions, which are largely expected to be...

The Research Paper commences with an overview of Pillar One and Pillar Two followed by detailed discussions on salient provisions of Pillar Two. Pillar Two is envisaged to have a widespread impact on Small Island Developing States (SIDS) which are a distinct group of 38 United Nations (UN)...