Increasingly linked by regional and global ties, national economies depend more than ever on international investments and trade. While trade and investment have become international, however, taxation has remained national, preserving and strengthening one of the few remaining barriers to...

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...

Article 13 of the OECD Model tax treaty allows a source country to retain taxing rights on capital gains realized by non-residents on the sale of real (immovable) property in the source country. Recently, it has been modified to incorporate a further rule that has long been a feature of the UN...

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...

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

This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and...

This paper was specifically written for a Swedish tax journal and its audience. As a result, it assumes that the audience is less knowledgeable about the UN tax treaty model (UN MTC) and the general situation concerning the power relationship between the global north and south compared to, for...

In 2013, the Organization for Economic Cooperation and Development (OECD) launched its base erosion and profit shifting (BEPS) project to inhibit aggressive international tax planning. Action 1 of the BEPS project requires the OECD to identify the main challenges that the digital economy poses...