This paper discusses tax policy measures to reduce corporate tax avoidance by extending taxation in the source country without imposing double taxation. We focus on four options: Bilaterally restricting interest and royalty deductibility, introducing an inverted tax credit system, levying...

There is an ongoing extensive debate, virtually touching each jurisdiction, regarding the levy of taxes on digital services. Each country, especially the Source countries which have an extensive consumer base of digital services, is grappling with the increasing pressure to tax such services...

Double taxation agreements pose a particular analytical problem. While they provide a coherent structure that encourages cross-border investment, the agreements also provide opportunities for taxpayers to avoid their domestic tax obligations. To prevent tax avoidance, some countries enact...

This study provides an interdisciplinary analysis of firm theory and international tax law, applied within a framework of hypothetical illustrations of prototypical multinational enterprises. The study finds that the construct and interpretation of different norms of international tax law...

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...

Much has been said and written about the ‘fiscal behaviour' of multinationals. A tax code of conduct is often mentioned as a 'catch-all solution' for stimulating 'acceptable fiscal behaviour'. Stakeholders increasingly demand fiscal accountability to obtain verifiable and validated credible...

Increasingly linked by regional and global ties, national economies depend more than ever on international investments and trade. While trade and investment have become international, however, taxation has remained national, preserving and strengthening one of the few remaining barriers to...

This article explores a long-standing research and policy question on whether tax incentives for charitable giving are desirable from legal and economic perspectives. The author discusses legal and empirical aspects that are important in designing tax incentives for charitable giving. Firstly,...