The proposed OECD Pillar One and Two reforms mark a significant shift in the way large multinational enterprises are taxed on their global incomes. However, while considering the reform at the proposed scale tax administrators must be able to compare the revenue gains with alternatives. This...

In October 2015, the OECD/G20 presented their final report on the Base Erosion and Profit Shifting (BEPS) Project. This article presents a unique analysis of the OECD/G20's recommendation on Action 4 by utilising tax optimisation modelling to simulate and examine a hypothetical multinational...

A lion's share of global investments is likely being conducted for tax avoidance purposes via controlled foreign companies (CFC) which are established in tax havens or low tax jurisdictions. Avoiding tax via CFCs causes several problems, in particular it: (i) leads to unfair and unbalance...