Transfer pricing remains an inevitable tool for MNCs to carry out intra-company transactions. From the literature, misuse of transfer pricing has been observed with respect to advertisement, marketing and promotion (AMP). This research paper attempts to demonstrate the instances wherein abuse of...

This paper analyzes the role of Tax Incentives in promoting investment, their effectiveness and their revenue and other costs and political economy. The paper consolidates econometric work on the topic done by the authors covering the Caribbean, Francophone Africa and India; surveys of Investors...

Cederwall discusses the Tax Foundation's virtual colloquium, "Making Sense of Profit Shifting" — featuring 18 leading tax scholars, practitioners, and policy experts — and explains how it reveals six significant themes of incongruence in the understanding of profit shifting. Cederwall...

Government subsidies to higher education have recently become a hot button political issue. But what if the federal government doesn't actually subsidize higher education, but rather, taxes it? This article gauges efficient investment levels based on marginal rates of return relative to other...

Abuse is one of the core issues in EU direct tax matters. Much has been written over the past years. The discussion on the interpretation and application of the different elements of the anti-abuse clauses appears to be settling. However, an equally fascinating discussion appears to be emerging:...

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,...

Without a stable and adequate tax base, countries lose the financial capacity to provide the infrastructure, social services and development opportunities important to their citizens. In response, the G20 and the Organisation for Economic Co-operation and Development (OECD) organized the project...

Viewing the development of the standard international tax neutrality discussion as being historically fairly limited because Musgrave's conclusions, rather than basic definitions, served as the undisputed baseline, in a previous article I reconsidered the classic international tax neutrality...

Tax policy in general and international income tax policy in particular has long been a subject of discussion and argument by tax philosophers, economists, and lawyers. Theories have often been introduced to support the establishment of new tax systems, to justify existing ones, or to call for...

Using a 30-year panel of quarterly GDP fluctuations from of a broad set of countries, we demonstrate that the signing of a bilateral tax treaty increases the comovement of treaty partners' business cycles by 1/2 a standard deviation. This effect of fiscal policy is as large as the effect of...