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...

In this paper, we attempt to estimate the tax revenues to be gained by the Member States of ATAF, WATAF, AU and the South Centre under the Amount A and an alternative stylized DST taxation regime. Our research demonstrates that the comparative revenue effects of the Amount A and DST taxation...

U.S. taxpayers and the IRS increasingly have to take into account the interactions between U.S. and foreign laws, but they have paid little attention to the administrative law backgrounds of foreign tax laws. In a growing range of cases, the need for such attention has become urgent. This...

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)...

This article is concerned with the role of tax planning in Chinese MNCs foreign direct investment (FDI) decisions. It can be shown that tax planning (intragroup debt financing) enables Chinese firms to locate value-added chain and direct investment (e.g. production) in high-taxed foreign...

Chinese double tax treaties define the territory of China in a broad sense and prima facie Hong Kong is included within the territory of China. However, the Chinese and Hong Kong authorities, as well as all of China's treaty partners, take the view that Hong Kong is not covered by Chinese tax...

This paper argues that, the past ten years is an unprecedented “golden decade” for tax treaties policy in China to take shape. The rapid developments have been closely interwoven with the economic, legal and institutional reforms that have taken place within the country in the larger scale,...

The Belt and Road Initiative (BRI), as one of the most remarkable events of international economic cooperation nowadays, has noticeable implications for many areas of study. This article is to explore how BRI, an initiative proposed and championed by China, has influenced China's international...