The impact of the U.S. bilateral tax treaty system on inbound and outbound foreign direct investment arguably is more important than the effect of U.S. domestic law on foreign direct investment. However, the tax treaty process lacks comprehensive examination of general economic and specific...

This contribution identifies the main determinants and key persons that constituted the tax treaty policy of the Netherlands. This policy is rooted in the political chess games in 19th century mainland Europe. In this century, European states gained experience in negotiating trade and tax...

Viewing the development of the standard international tax neutrality discussion as being historically fairly limited because Musgrave's conclusions, rather than basic definitions, served as the undisputed baseline, in a previous article I reconsidered the classic international tax neutrality...

Tax policy in general and international income tax policy in particular has long been a subject of discussion and argument by tax philosophers, economists, and lawyers. Theories have often been introduced to support the establishment of new tax systems, to justify existing ones, or to call for...

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 describing...

The report discusses the initial implementation of BEPS in Poland: legislative responses to BEPS measures, including policy choices made in this regard by the Polish tax administration and participation of stakeholders in the process. It reflects the state of play as of November 2016

This article considers the residence-related income tax treaty aspects of nonincome taxes such as the retail sales tax, the value added tax, the flat tax, the X tax, the destination-based cash flow tax, and certain turnover taxes, and discusses the related treaty aspects of the concepts of tax,...

The aim of this paper is to assess the feasibility to introduce the OECD-BEPS measures to deal with aggressive tax planning in South America and Sub-Saharan Africa. The BEPS and its Action Plan have been developed by the OECD following the G20 mandate and it provides new international tax...

This article aims to analyse the multilateral action and instruments that have been and are being developed by the Organization for Economic Cooperation and Development (“OECD”) to enhance transparency and exchange of information and the Base Erosion Profit Shifting (“BEPS”) Project in...