The OECD has steered clear of including any references to EU law requirements in its 2014 Deliverables of the BEPS Action Plan. Otherwise, non-EU Member States might have gotten the impression that any future recommendations on how to curb BEPS will eventually not be fully implemented in Europe....

The Action Plan on Base Erosion and Profit Shifting (Action Plan) intends to “revamp” the work on harmful tax practices that has been undertaken by the Organisation for Economic Co-operation and Development (OECD) since the late 1990s. Further enhancement of the OECD's transparency...

Die Reform der Unternehmensbesteuerung verfolgt das Ziel, mehr Investitionen und Arbeitsplätze in Deutschland zu halten und die Verlagerung von Buchgewinnen in Niedrigsteuerländer einzuschränken. Gleichzeitig sollen die Steueraufkommensverluste möglichst gering gehalten werden. Dieser...

The predominant model of tax induced transfer pricing is based on the assumption that profit shifting is due to insufficient enforcement. However, evidence shows that the firms responsible for most profit shifting are also among the most frequently audited. We present an alternative model based...

We present a new model of tax induced transfer pricing as an alternative to the oft-used concealment model. Inspired by interviews with practitioners, we consider a large multinational firm which is audited by the tax authority in the high-tax location. When this country adjusts the transfer...

We present a new model of tax induced transfer pricing as an alternative to the oft-used concealment model. Inspired by interviews with practitioners, we consider a large multinational firm which is audited by the tax authority in the high-tax location. When this country adjusts the transfer...