The article looks at exit taxation within the European Union, including how it affects cross-border mergers. It starts with an explanation of the concept of exit tax, followed by an analysis of the current legislation and an analysis of the case law of the European Court of Justice. The article...

A number of regional trade agreements (RTAs) include investment protection provisions that may limit a country’s ability to change tax measures. This limitation could raise concerns for States as regards the recently agreed global minimum tax under the Global Anti-Base Erosion (GloBE) Rules,...

Using a large panel dataset on worldwide operations of multinational firms, this paper studies one of the most advocated anti-tax-avoidance measures: Controlled Foreign Corporation rules. By including income of foreign low-tax subsidiaries in the domestic tax base, these rules create incentives...

This paper examines the impact of Japan's 2009 adoption of a territorial tax regime using event study methods which leverage individual firm characteristics to identify underlying drivers of market reactions. Differences in Japanese firms' foreign and domestic effective tax rates yield an...

This article briefly assesses the “venture capital friendliness” of four Central European tax/legal jurisdictions (Poland, Hungary, the Czech and Slovak Republics) following their European Union (EU) accession – in May 2004. It is noteworthy that, notwithstanding the heated debate on tax...

Within the European Union, there exists a fundamental tension between the fiscal sovereignty of its Member States, in particular in the field of direct taxation, and the requirements of the Internal Market, which aim at the abolition of any regulatory or fiscal obstacles to cross border movement...

I propose to use tax incentives to attract foreign direct investments (FDI) to developing countries to promote growth, and explain what practical and conceptual changes in the tax systems of developing as well as developed countries (introducing a notion of inter-nation equity) should be made to...

Tax treaties are often viewed as a mechanism for eliminating tax competition, however this approach ignores the need for bargaining over the treaty's terms. This paper focuses on how bargaining can affect the withholding taxes set under the treaty. In a simple framework, we develop hypotheses...

What are the implications of the rapid growth in offshored business services for transfer pricing, the pricing of products traded between affiliated firms? We explore these implications through a case study of transnational corporations in the teleservices industry. Teleservices TNCs own foreign...

This paper discusses the 2005 proposal of President Bush's Advisory Panel on Federal Tax Reform to enact a dividend-exemption system for certain foreign-source earnings of U.S. taxpayers. The paper briefly explains why the recommendation should be an improvement over current law, compares it to...