After an explanation of the purpose of this study, the rest of this article is organized as follows: section 2 briefly considers the theoretical legal background for a withholding tax on (technical) services. Section 3 contains the heart of the essay comparing the pros and cons of the new...

There are about 2,600 double tax treaties in the world, some 500 among industrialized economies, approximately 800 among developing economies and about 1,300 between industrialized and developing economies. Whereas the prior two categories are symmetric, the latter is asymmetric, as capital...

The OECD Programme of Work on the tax challenges arising from the digitalization of the economy encompasses a so-called GloBE (Global Base Erosion) or Pillar 2 proposal, consisting in a series of measures aimed at establishing a floor to tax competition by achieving minimum taxation in all...

In this research paper, we attempt to estimate the tax revenues to be gained (or lost) by the South Centre and African Union's Member States under the Amount A and Article 12B regimes. Our analysis relied on sources of information available to private sector researchers but did not involve...

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...

The governments of many developing countries seek to attract inbound foreign direct investment (FDI) through the use of tax incentives for multinational corporations (MNCs). The effectiveness of these tax incentives depends crucially on MNCs' residence country tax regime, especially where the...