The October 2020 Pillar One proposal by the OECD/Inclusive Framework (IF) is designed to shift some portion of the global pre-tax profits of multinational enterprises (MNEs) in automated digital services (ADS) and consumer-facing businesses (CFB) to Market jurisdictions where ADS and CFB...

This paper outlines and examines the taxation implications (primarily income tax) for residents of the United Kingdom (UK) and Australia also citizens and permanent residents of the United States (US) who are employed overseas. In addition to identifying specific taxation implications for...

The 2017 Tax Cut and Jobs Act reduced the US corporate tax rate and introduced provisions to curb profit shifting. We combine survey data, tax data, and firm financial statements to study the evolution of the geographical allocation of US firms' profits after the reform. The share of profits...

This chapter from a Practical Guide to Transfer Pricing (Lexis) compares the U.S. Section 482 transfer pricing regulations to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations as revised in 2010. Section 482's purpose is to ensure that taxpayers subject...

It has become clear that over the past few decades enterprises not only produce and sell abroad but increasingly also develop goods and services outside their home countries; a development now known as the internationalisation of business R&D. This book presents a comprehensive picture of the...