Tax avoidance by major US multinationals has been extremely topical over the last decade since the GFC. One of the MNEs at the forefront of this controversy is Google. It has been able to snare a dominant share of the international online advertising market without paying any significant amounts...

The aim of this article is to point to a flaw in one of the measures recently enacted by the New Zealand Government to prevent tax avoidance by large multinational enterprises (MNEs). That measure is section GB 54 of the Income Tax Act 2007, which was added to the Act in July 2018 and which is...

This study investigates how strategic tax transfer pricing of a multinational company (MNC) and two tax authorities in different countries affects production and tax avoidance decisions at the firm level and tax revenues at the country level. We employ a game-theoretical model to analyze the...

This study investigates how strategic tax transfer pricing of a multinational company (MNC) and two tax authorities in different countries affects production and tax avoidance decisions at the firm level and tax revenues at the country level. We employ a game-theoretical model to analyze the...

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...

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...

Within a close system of legal rules, it is almost impossible to combat the abuse of offshore business and tax haven-related transactions. This is first because international business lacks even the fundamental sources of law. Secondly, even if international business were fully covered by...

The issue of General Anti-Avoidance Rules and treaties is a legal problem as old as double tax conventions themselves. However, the BEPS Project, materialized in 15 Actions and particularly in the Final Report of BEPS Actions 6, involves a radical change in the very physiognomy of the problem....

Looking at collective investment schemes from a financial law perspective seems to stand in harsh contrast to the OECD's perspective as expressed in the materials to BEPS Item 6. While financial lawyers emphasize the use of collective investment schemes – for manifold-financial relationships...