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...

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 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...

The article deals with the interesting issue of the tax treaty qualification problems arising in hybrid financial instruments and structures. The need to fit the great diversity of instruments and legal, economic and accounting trends attached to them into the closed range of treaty income...

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...

One of the aims of the BEPS Action Plan is to reduce existing leeway for multinational enterprises to shift profits by exploiting transfer pricing rules. Profit allocation is meant to be aligned with “real activity” and “value creation.” This article is devoted to the question of whether...