This note reviews May 2019 OECD framework agreement report, “OECD/G20 Inclusive Framework on BEPS: Progress Report July 2018-May 2019” on international taxation of the ‘digital economy'. The core conclusions of the review are:1. The framework agreement proposals to-date represent complex,...

This paper assesses whether conditionality in IMF-supported programs has helped offset the potential negative effect of foreign aid on tax revenues. The analysis - carried out on panel data covering 1993-2012 for 111 low- and middle-income countries - shows that growing use of revenue...

This position paper of the IBFD Academic Task Force (hereinafter IBFD Task Force) relates to the OECD's work on BEPS Action 1 and is devoted to withholding tax aspects. This position paper provides possible solutions to the challenges presented to the international tax regime by the digital...

This paper outlines the core issues of the introduction of a new PE nexus based on digital presence. It puts forward its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global economy. Our proposal of a new PE nexus based on digital...

This article examines the role that international comparisons play in current corporate tax reform discourse in the United States. Citing the need to make the U.S. corporate tax system more competitive, comparisons are frequently used to assess other jurisdictions' tax-competitiveness, and many...

In light of the UK Coalition Government's announced intention to reform APD (Air Passenger Duty), this article examines the design flaws making APD an inadequate environmental tax. By identifying the misconceived consequences and environmental inefficiencies of this blunt instrument, the need...

This document is the final report of the Consultative Committee on Full Imputation and International Tax Reform. This final report outlines the Committee's recommendations on the outstanding issues relating to both sets of reforms. It explains the policy behind draft legislation produced by the...

This document is the first part of the report on the introduction of international tax measures by the Consultative Committee on Full Imputation and International Tax Reform. The report sets out the major building blocks of the regime recommended by the committee following its review of the...

Justice Edmonds' judicial output was large, but it did not prevent him from presenting several extra-judicial speeches and papers every year. These represent an impressive body of work: both scholarly and practical. In these writings, Edmonds J analyses the Australian tax system and advocates...

The article aims to appreciate the U.S. tax reforms, especially in topics related to international taxation, emphasizing the analysis of their potential incompatibility with the World Trade Organization (WTO) law. It will be discussed in the U.S. international tax environment before the U.S. tax...