This article is focused on the Court's decision in Hornbach-Baumarkt (Case C-382/16) (Hornbach) which is an important clarification of the conditional compatibility of arm's length-based domestic transfer pricing legislation with the freedom of establishment. Hornbach follows and confirms the...

Die Abgrenzung des Erfolges multinationaler Unternehmungen (MNU) für körper-schaftsteuerliche Zwecke erfolgt im Regelfall im Rahmen des Fremdvergleichsgrundsatzes, konkretisiert durch die Transferpreisrichtlinien der OECD. Dieses Erfolgsabgrenzungsparadigma steht im systematischen Gegensatz zu...

Critical tax theory identifies systemic imbalances in taxation that impose disproportionally high tax burdens on groups who lack or fail to exercise political power. This article focuses on foreigners as an ideal taxpaying group because it does not vote. The article identifies some ways in which...

This paper investigates the equity market reactions to the publication of the OECD BEPS Action Plan. We examine abnormal stock returns for firms incorporated and traded on the stock market in 36 OECD member states for various event dates during the developmental phase of the OECD BEPS Action...

We exploit a 2015 regulatory change in the European value-added tax (VAT) system to study how multinational companies (MNCs) respond to taxation on the basis of the location of their customers (destination-based taxation), rather than based on their location of incorporation (origin-based...

This paper assesses the importance of taxation on foreign direct investment contributing to the literature in two ways. First, it relates bilateral FDI among OECD countries over the 1990s to a new set of estimates of corporate tax wedges that include many relevant aspects of FDI taxation....

This paper uses a strategic tax compliance model to examine taxpayer reporting and tax authority audit strategies in an international setting with two tax authorities. The setting features both information asymmetry between the taxpayer and the tax authorities and tax law ambiguity. The latter...

International corporate tax avoidance by multinational enterprises likely lowers the Czech Republic's corporate income tax revenue, but it is not clear by how much. To clarify this I first review existing estimates of the costs of international corporate tax avoidance to government revenue...

This paper analyzes the switch from Separate Accounting to Formula Apportionment in a dynamic framework. The model features both purely domestic corporations and a domestic multinational which invests at home and abroad as well as a purely foreign corporation and a foreign multinational which...

Anecdotal evidence often suggests that multinational enterprises (MNEs) operating in developing countries “exploit their multinationality” to avoid paying taxes to host governments. This article explores the concept of “responsible tax” as a corporate social responsibility (CSR) issue...