This paper elaborates on the emergence of so-called Advance Pricing Agreements (APA) in international taxation and corresponding APA programs in individual countries. It refers to how globalizing business processes trigger governance change on the nation state level regarding the identification...

This analysis refers to the emergence of so-called Advance Pricing Agreements (APA) in international taxation and corresponding APA programs in individual countries. APAs are a type of non-bureaucratic, cooperative governance that exists between the multinational corporate taxpayer and the...

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 article springs from two concurrent phenomena. First, U.S. federal deficit spending projections indicate that any feasible deficit reduction plan will require substantial additional revenue. Second, the U.S. system for taxing foreign-source income is so badly flawed that if the United...

The Russian system is not yet capable of running on its own, without Putin amid internal and external challenges and threats.Russian youth sees him as a hero; photos, participating in skiing, fishing, hunting, judo, hockey, ice dip in sub zero freezing water to mark Epiphany, and horse riding...

This paper investigates the effects of double tax treaties (DTTs) on foreign direct investment (FDI) after controlling for their relevance in the presence of treaty shopping. DTTs cannot be considered a bilateral issue, but must be viewed as a network, since FDI can flow from home to host...

The costs of doing business internationally are many. Economizing on such costs is essential to be globally competitive. In this context, a rather overlooked area of cost reduction is the refund of global VAT incurred abroad on business expenses. A large number of exporters across the world do...

The overwhelming complexity of transfer pricing within income taxation and the number of available materials generates significant entry barriers for conducting adequate research in this field. The objective of this contribution is to briefly depict the most relevant issues and provide basic...

Despite the inherent complexity that the enforcement of transfer pricing rules entails, it is feasible—and desirable—to introduce simplification measures without abandoning this worldwide accepted standard, especially in the context of developing countries and despite reticence shown by...

This article seeks to explain recent decisions by countries to terminate their existing bilateral investment treaties (BITs) and revisit their commitment to future international investment agreements (IIAs). It argues that BITs, transnational corporations (TNCs), host States and international...