world, how and why these firms behave the way they do is a major issue for national governments and their policymakers. With … corporations have become increasingly sensitive to the kind and degree of tax obligations imposed on them by both host and home … countries. Tax rules affect the volume of foreign direct investment, corporate borrowing, transfer pricing, dividend and royalty …

to establish a new global framework for tax. This paper analyses the defects of international tax rules as applied to … have become increasingly important for economic development, but international tax rules favouring delivery by non … are mainly hosts to MNEs. We analyse the restrictions on source taxation of services in tax treaties, particularly those …