This paper investigates the effects of double tax treaties (DTTs) on foreign direct investment (FDI) after controlling … shopping, we calculate the shortest (i.e. the cheapest) tax distance between any two countries allowing the corporate income to … be channelled through intermediate jurisdictions. We differentiate between relevant and neutral DTTs - i.e. tax treaties …

Recent years have seen a dramatic increase in the attention given to abusive tax schemes that take advantage of … bilateral tax treaties. The ensuing discourse tends to view potential responses to treaty abuses as a hierarchical set of … responses based on the type of treaty abuse at issue.This article develops a taxonomy of tax-treaty abuses based on two factors …

We investigate the outcome of bilateral tax competition by analyzing Double Tax Treaties (DTT). DTTs are the crucial … means of splitting a tax base between two countries. Yet, there are only few empirical results on the textual design of DTTs …

Legal fictions have been included in various tax laws in many countries. In respect of tax treaties, they may give rise … to various questions, such as:• Does the inclusion of a legal fiction in a national tax law after the conclusion of a tax … treaty constitute tax treaty override?• Does the inclusion of a legal fiction in a national tax law before the conclusion of …

Typically, the tax treaty entitlement to fiscally transparent entities (‘FTEs’) has been a matter of debate in the … arena of international tax. FTEs are not taxed at the entity level but at the level of the persons who have an ownership … interest in that entity. Hands down, it is one of the most complex spheres of the tax treaty law.The crux of this complexity …

In this research paper, we attempt to estimate the tax revenues to be gained (or lost) by the South Centre and African … private sector researchers but did not involve review of any information that taxpayers provide to tax authorities. Our …

A lion's share of global investments is likely being conducted for tax avoidance purposes via controlled foreign … companies (CFC) which are established in tax havens or low tax jurisdictions. Avoiding tax via CFCs causes several problems, in … that may further adversely affect sustainable development; (iii) erodes the tax base of the States that undermines the …