A key motivation underlying the October 2020 OECD Pillar One and Pillar Two Blueprints is the goal of reducing tax complexity for taxpayers and tax authorities. In this article, we assess the tax complexity of the Blueprints relative to the 2017 OECD Transfer Pricing Guidelines (TPG) and the...

Hong Kong is not a tax haven, but is probably the only international financial centre that is not covered by a Double Tax Agreement (DTA). The relevant DTAs between the People's Republic of China (PRC) and the UK, the PRC and Australia or the PRC and the US do not apply to Hong Kong. This is...

The 135 member countries in the OECD/G20 Inclusive Framework on BEPS are considering the adoption of a global minimum corporate income tax for taxing multinationals as part of the Pillar Two (GloBE) proposals for taxing the digital economy. This article provides a detailed analysis of the global...

The 135 member countries in the OECD/G20 Inclusive Framework on BEPS are considering the adoption of a global minimum corporate income tax for taxing multinationals as part of the Pillar Two (GloBE) proposals for taxing the digital economy. This article provides a detailed analysis of the global...

UN Resolution 77/244, adopted by the General Assembly on 30 December 2022, reaffirms earlier commitments by the United Nations to improve international tax cooperation, fight illicit financial flows, and combat aggressive tax avoidance and evasion. The resolution asks that the Secretary-General...

This article investigates and measures the frequency, fairness, and efficacy of exit bans in China. We limit our definition of “exit bans” to civil business disputes between a foreign businessperson and his or her local Chinese counterpart, where the foreigner is prevented from leaving...

This paper analyzes the impact of taxes and lending conditions on the financial structure ofmultinationals' foreign affiliates. The empirical analysis employs a large panel of affiliates ofGerman multinationals in 26 countries in the period from 1996 until 2003. In accordance withthe theoretical...

This paper analyzes the effectiveness of thin-capitalization rules in preventing debt financeby intercompany loans and explores their consequences for corporate decisions. A theoreticaldiscussion emphasizes that limitations of the deduction of interest owed to foreign afiliateswould not only...

We study the impact of transfer pricing rules on sales prices, firms’ organizational structure, andconsumers’ utility within a two-country monopolistic competition model featuring source-basedprofit taxes that differ across countries. Firms can either become multinationals, i.e., they serve...