The paper evaluates the working of German CFC rules that restrict the use of foreign subsidiaries located in low-tax countries to shelter passive investment income from home taxation. While passive investments make up a significant fraction of German outbound FDI, we find that German CFC rules...

The game Prisoner's Dilemma provides a helpful tool for understanding international tax competition. Nations would be best served by cooperating with each other to keep corporate income tax rates high. But fearing defection by other nations, many nations often unilaterally lower their corporate...

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 policy brief is aimed at the decision-makers in the Ministry of Finance of Indonesia which seeks the best policy response to the global minimum tax agreed by 137 countries on the 8th October 2021 (Global Base Erosion Rule (GloBE) – also known as the Pillar Two Proposal). It explores how...

This paper examines the effects of the Tax Reform Act of 1986 on the international location decisions of U.S. financial services firms. The Act included rule changes that made it substantially more difficult for U.S. firms to defer U.S. taxes on overseas financial services income held in low-tax...

In their famous Mirrlees review (2011) on reforming the tax system for the 21st century, the authors put forward the introduction of an allowance for corporate equity regime. In recent years, several countries introduced an ACE regime. The main feature of an ACE regime is that it removes tax...

We exploit the 2017 US tax reform to learn about the tax-competitiveness of US multinational corporations (MNCs) relative to their international peers. Matching on the propensity score, we compare pairs of similar US and European firms listed on the S&P500 or StoxxEurope600 in a...

The cash-flow tax has been proposed as an alternative to corporate income tax on grounds of clarity and simplicity in defining the tax base in the face of widespread departures from the comprehensive income tax in actual practice. Variants of the tax, with their advantages and disadvantages,...

This work undertakes a comprehensive analysis of the U.S. state experience under formulary apportionment of corporate income. While formulary apportionment eliminates the possibility of shifting income across states through accounting strategies that manipulate where income is booked, it may...