Over the past few years, policymakers have argued that everything from Apple's Irish tax deal to patent boxes to the LuxLeaks tax rulings represent “harmful tax competition.” Despite the ubiquity of this term, however, there is no internationally accepted definition of so-called harmful tax...

The OECD Programme of Work on the tax challenges arising from the digitalization of the economy comprises a so-called GloBE (Global Base Erosion) or Pillar Two proposal, consisting of a series of measures aimed at establishing a floor to tax competition by achieving minimum taxation of the...

The main purpose of this book is to promote the dissemination of the basic notions of taxation from a policy, legal and administrative perspective, offering its readers a balanced view of rights and obligations connected with the levying of taxes. The book sets out current principles of taxation...

This paper develops a competition theory framework that evaluates an important aspect of the OECD's Harmful Tax Practices Initiative against tax havens. We show that the sequential nature of the process is harmful and more costly than a "big bang" multilateral agreement. The sequentiality may...

We develop a tax competition framework in which some jurisdictions, called tax havens, are parasitic on the revenues of other countries. The havens use real resources to help companies camouflage their home-country tax avoidance, and countries use resources in an attempt to limit the transfer of...

In recent years, profit shifting by multinational companies has generated substantial revenue costs to the U.S. government. The Tax Cuts and Jobs Act (TCJA) changed the climate for profit shifting in several important ways: the lower U.S. corporate rate should lower the incentive to shift...

In the public debate on taxation, fairness has become a prominent issue over the past few years. In the 1950s legal philosophers have developed a definition of the principle of fairness which focuses on the relationships between tax payers and the expectations they have of each other. It is this...

Can a WTO Member discriminate against foreign suppliers of services located in jurisdictions that refuse to share information with a government to permit it to determine if its nationals engage in tax evasion? Does it matter if the Member uses standards developed by an international body as the...

With the election of Donald Trump and the Republican Party's domination of Congress, House Speaker Paul Ryan's blueprint for fundamental tax reform requires more careful analysis. The Ryan blueprint combines reduced individual rates with a destination-based cash flow type business tax applicable...