As part of the Organisation for Economic Co-operation and Development's Base Erosion and Profit Shifting project, country-by-country reporting (CbCR) has been promoted as a mechanism to enhance transparency with respect to the operations and tax planning activities of large multinational...

In 2013 the OECD released its 15-point action plan to deal with base erosion and profit shifting (BEPS), which recognised that BEPS has a significant effect on developing countries because the lack of tax revenue can lead to a critical underfunding of public investment that would help promote...

This paper explores the question whether entering into double tax treaties leads to more foreign investment. The topic has been the subject of a number of studies that have generated inconsistent results. The paper reviews previous studies and notes the limitations that may have affected their...

China attracted considerable foreign investment following the opening of its economy in 1979. With the switch to a quasi-market economy, China became reliant on taxes to fund government, opening the door to potential double taxation of profits from foreign investment, first in China and second...

This chapter examines the historical development of the formulary apportionment approach in key jurisdictions.From the time income taxes were first widely enacted, tax designers have been concerned with the question of how to allocate profits in transactions that incorporated labour, capital or...

The SNF case in Australia revealed that in Australia a court could interpret domestic transfer pricing rules differently from those in Australia's tax treaties. In particular, the court rejected the use of OECD transfer pricing guidelines to determine an arm's length price under domestic law....