It is widespread practice around the world that corporate entities pay taxes to the country where they are formally registered and to the country in whose territory they generate income. While the former is generally known as the "country of residence" the latter is usually referred to as the...

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...

The Unified Approach issued by the OECD Secretariat on Oct 9, 2019, is the OECD's most recent attempt to find international consensus on BEPS Action Item 1, “Taxing the Digital Economy.” Our assessment is that the Pillar One proposals in the Unified Approach suffer from several defects, the...

The sun is setting on the days when multinationals could establish intricate tax systems to drastically reduce their tax bills. Since the 1990s, the OECD and the EU have taken resolute steps to compel their members to eradicate corporate tax elusion and harmful tax competition. These solutions...

One of the tax base erosion and profit shifting (BEPS) schemes that has been a major concern in developing countries over the last few years is the “offshore indirect transfer” of business assets to low-tax jurisdictions that facilitate tax planning so as to avoid capital gains tax in the...

This article seeks to assess why current transfer pricing rules are the source of tax avoidance and explore some possible remedies. It places transfer pricing rules in the overall context of taxing international business income in the situation of a widely held corporate group operating in...

International corporate tax is an important source of government revenue, especially in lower-income countries. An important recent study of the scale of this problem was carried out by International Monetary Fund researchers Ernesto Crivelli, Ruud De Mooij, and Michael Keen. We first...

International corporate tax avoidance by multinational enterprises likely lowers the Czech Republic's corporate income tax revenue, but it is not clear by how much. To clarify this I first review existing estimates of the costs of international corporate tax avoidance to government revenue...