The proposed OECD Pillar One and Two reforms mark a significant shift in the way large multinational enterprises are taxed on their global incomes. However, while considering the reform at the proposed scale tax administrators must be able to compare the revenue gains with alternatives. This...

This chapter offers the first global taxonomy of treaty dispute patterns emerging in the almost first 100 years of the international tax regime (ITR). The time and space dimensions of the taxonomy are as follows. The time dimension covers the era which ran from 1923 — when four economists...

In the context of international tax coordination incomplete information is one of the well-known frictions that can lead to bargaining failure and might explain a lack of observed coordination. We consider international negotiations about tax coordination under complete and incomplete...

This paper evaluates the Multilateral Convention to implement Pillar I Amount A, released by the OECD in October 2023, and the alternative proposal of Art. 12B for tax treaties suggested by the UN, with a particular emphasis on the perspective of developing countries. We conduct a comparative...

The chapter concerns limitations of bilateral tax treaties in multilateral situations (triangular cases). Such limitations result from the bilateral nature of tax treaties. Tax treaties based on the OECD Model or the UN Model are concluded by two parties, aiming to resolve juridical double...