This paper investigates the consequences of a series of alternative international tax designs on the strategy of a multinational enterprise regarding the cross border distribution of its investment and the choice of its financing behavior. We start with a world where no international tax rules...

To what degree developing countries gain from signing double tax treaties is being hotly debated. In this paper, we analyze the Austrian tax treaty policy. Combining legal and economic perspectives, we find that developing countries are likely to expect both positive and negative impacts from...

This position paper of the IBFD Academic Task Force (hereinafter IBFD Task Force) relates to the OECD's work on BEPS Action 1 and is devoted to withholding tax aspects. This position paper provides possible solutions to the challenges presented to the international tax regime by the digital...

This paper outlines the core issues of the introduction of a new PE nexus based on digital presence. It puts forward its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global economy. Our proposal of a new PE nexus based on digital...

If interpreted in a strict legal sense, beneficial ownership rules in tax treaties would have no effect on conduit companies because companies at law own their property and income beneficially. Conversely, a company can never own anything in a substantive sense because economically a company is...

This paper analyses the characteristics of transfer pricing systems across countries, in order to identify the grouping structures intrinsically related with rules' similarities, and to explore the key characteristics revealed by each group. Applying hierarchical agglomerative technique for...

The author discusses the International Tax Transparency in Venezuela after the implementation of the worldwide taxation system. A detailed analysis is made of the law providing the legal, economic and potential consequences of the use of tax havens by Venezuelan taxpayers. Finally, the issue of...

In 1990, Colombia started a process of liberalization through which the traditional scheme of 'production towards domestic necessities' was left behind. In consequence, reforms in the tax, financial, foreign trade and constitutional systems took place. These reforms aimed at removing obstacles...

To reduce tax evasion, most nations use either common law anti-abuse doctrines, statutes, administrative rules, or a combination of the three. None of them have worked fully, and, given human nature, it is unlikely that anything will ever work fully. However, as this Article will outline, some...

This paper investigates the consequences of a series of alternative international tax designs on the strategy of a multinational enterprise regarding the cross border distribution of its investment and the choice of its financing behavior. We start with a world where no international tax rules...