One of the most notable examples of U.S. tax exceptionalism is the taxation of U.S. citizens and legal permanent residents (LPRs) on their worldwide income, regardless of residence. The United States also imposes broad and increasingly onerous tax and financial reporting obligations on its...

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...

Profit shifting activities of multinational enterprises (MNEs) result in base erosion in high-tax countries. Tax-motivated profit shifting may distort real investments of MNEs and encourage economies to engage in tax competition. To address the loss of tax revenues in high-tax jurisdictions, the...

The multiplication of direct investment in Indonesia is not equal to adequate tax regulations. In turn, it creates loopholes for the minimisation of tax burdens through thin capitalisation. The purpose of this research is to analyse the factors affecting tax avoidance using thin capitalisation....

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...

The popular view is that governments should crack down on tax avoidance by multinational firms. In this paper, we analyze how anti-profit-shifting policies influence fiscal competition. Governments commit to profit shifting control effort and then set taxes on capital. Equilibrium tax rates are...

The research revolves around the topic of offshore destinations and role of tax in the decision where to locate TNCs’ investments or relocate employees. This paper exploits rich country-by-country reporting (CbCR) data that banking institutions operating in the EU with annual turnover over 750...

The World Customs Organization (WCO) and the Organization of Economic Cooperation and Development (OECD) have begun considering the harmonization of transfer pricing norms among income tax, customs and VAT regimes. Two conferences have been organized in May of 2006 and 2007. These conferences...

Most papers on transfer pricing deal either with technical aspects of the topic or strategy. Research on ethical aspects of transfer pricing is almost totally absent from the business literature and is scantly covered in the ethics literature. The purpose of this paper is to fill that gap....