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 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...

Cederwall discusses the Tax Foundation's virtual colloquium, "Making Sense of Profit Shifting" — featuring 18 leading tax scholars, practitioners, and policy experts — and explains how it reveals six significant themes of incongruence in the understanding of profit shifting. Cederwall...

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...

This paper investigates whether the size of multinationals? real investments in a high-tax country is affected by profit shifting activities. A simple theoretical analysis shows that tax rates abroad impact the cost of capital in the presence of profit shifting activities of multinational...

We analyze the impact of tax loss treatment on the size and structure of multinational investments. Basically, two effects of tax loss treatment can be expected. First, firms make their investment decisions in the face of potential future losses. Then, the various types of conceivable loss...

This article studies the relationship between debt policies of multinational companies (MNCs) and governments' tax strategies. In the first part, it is shown that the ability to shift income from high- to low-tax countries affects MNCs' financial choices. In the second part we show how MNCs'...

Most existing empirical evidence on the impact of profit taxation on multinational firm activity is based on cross-country data. One major drawback of such data is that countries differ not only with regard to taxes but along other dimensions which might be hard to capture by means of observable...