1. Introduction -- 2. International Taxation and Transactional Models -- 3. Business Strategy and Transactional Models -- 4. Direct Business -- 5. Merchandize Business -- 6. Agency Business -- 7. Conclusion.

This paper discusses the issue of profit shifting and “aggressive” tax planning by multinational firms. The paper makes two contributions. First, it provides some background information to the debate by giving a brief overview of existing empirical studies on profit shifting and by...

Aggressive tax planning efforts of highly profitable multinational companies (Base Erosion and Profit Shifting (BEPS)) have recently become the subject of intense public debate. As a response, several international initiatives and parties have called for more transparency in financial reporting,...