The objective of this paper is to analyze the procedures used by multinational enterprises to distribute the income generated by its foreign subsidiaries, and how they allocate the taxes paid on this income through the fiscal jurisdiction in which they operate, from the institution based view....

Tax administrations are networking to create synergies. On the one hand, formal and informal network strategies are developed to increase their receipts at the expense of enterprise. On the other hand, governments also follow an industrial marketing approach of networking to add value to...

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...

This paper - written for an edited volume addressing how law and policy can keep pace with highly dynamic scientific and technological innovation - proposes an international framework to coordinate and facilitate national responses to innovations that may create significant risks or pose social,...

The taxation of the multinational enterprise (MNE) has been a continuing concern for policy-makers. We argue that the changing nature of the mobile MNE (e.g., its improved ability to fine-slice the value chain and disperse it geographically) makes it increasingly important to rethink current tax...

There have been numerous cross-border M&A deals involving transnational firms over the last 10 years, in many cases large deals involving European and/or US firms. Japanese firms see the need to expand their overseas presence in response to their low profitability, the maturation of the domestic...

We study the prevalence and traits of global collaborative patents for U.S. public companies, where the inventor team is located both within and outside of the United States. Collaborative patents are frequently observed when a corporation is entering into a new foreign region for innovative...