A recent KPMG transfer pricing study posits fixed percentages for returns to marketing and distribution activities, a.k.a. Amounts B and C in OECD parlance. The study casts some light on the OECD's design for a new global tax allocation respecting the profits of certain digital economy firms. By...

Foreign-owned subsidiaries make significant contributions to national Research and Development (R&D) in many host countries. Policymakers often support subsidiaries through R&D grants and R&D tax credits. A key objective of this funding is to leverage R&D-driven firm performance benefits for the...

We evaluate the 2017 Tax Cuts and Jobs Act. Combining reduced-form estimates from tax data with a global investment model, we estimate responses, identify parameters, and conduct counterfactuals. Domestic investment of firms with the mean tax change increases 20% versus a no-change baseline. Due...

The 2017 Tax Cuts and Jobs Act (TCJA) sharply reduced effective corporate income tax rates on equity-financed US investment. This paper examines the reform’s impact on US inbound foreign direct investment (FDI) and investment in property, plant and equipment (PPE) by foreign-owned US...

The OECD agreement in principle on a global minimum corporate income tax – Pillar II of the BEPS project – is a major step in international tax regulation and coordination. Yet, its consequences for foreign direct investment (FDI) have received limited attention thus far. The theme chapter...

This study examines the effect of the 2017 Tax Cuts and Jobs Act (TCJA) on capital investment, labor investment, and the productivity of foreign subsidiaries of U.S. multinational corporations (MNCs). Proponents of the TCJA argue it decreased foreign investment by leveling the playing field...

This study is focused on the tax measures that have been enacted in Portugal, following the health and economic crisis created by the SARS-CoV-2/COVID-19 pandemic.First, it aims at comprehensively characterizing the measures enacted, structuring them by thematic clusters, enabling the reader to...

The OECD’s Pillar One Blueprint, released on 12 October 2020, proposes to redistribute the taxable income of multinational enterprises (MNEs) away from jurisdictions that are home and host to MNEs to the markets where MNE products are sold. This article examines the OECD’s Economic Impact...

Cross-border mergers and acquisitions data show that for the first time since 2013, the dollar share of outbound transactions — that is, acquisitions by U.S. companies of foreign assets and companies — exceeded inbound transactions — that is, acquisitions by foreign companies of U.S....

This study was drafted shortly after the announcement of the referendum by which the United Kingdom decided to leave the European Union. In this article, the authors make a comprehensive assessment of what would be the tax consequences attached the decision. The article is of interest not only...