This article examines the compatibility of the OECD's proposed rules on GloBE (pillar II) with EU law, covering both primary law and secondary law. In addition, it discusses the amendments required by the implementation of this initiative within the internal market. In what concerns...

[EN] “Should I stay or should I go… ”? The implementation of the EU’s internal market, characterized in the Treaty on the functioning of the European Union ( TFUE) as ”an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured”,...

[EN] “Should I stay or should I go… ”? The implementation of the EU’s internal market, characterized in the Treaty on the functioning of the European Union ( TFUE) as ”an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured”,...

International corporate tax avoidance by multinational enterprises likely lowers the Czech Republic's corporate income tax revenue, but it is not clear by how much. To clarify this I first review existing estimates of the costs of international corporate tax avoidance to government revenue...

A growing number of leaks and scandals from tax havens have put tax avoidance by multinational companies on the political agenda. Yet under conditions of corporate financial secrecy, reforms remain incomplete and their impact on reducing illicit financial flows uncertain. This paper details how...

This article deals with the decision taken by the Court of Justice of the European Union in of 26 February 2019 in N Luxembourg I et al. (Joined Cases C-115/16, C-118/16, C-119/16 and C-299/16) and T Danmark et al. (Joined Cases C-116/16 and C-117/17).The authors acknowledge that the "Danish...

The Homeland Investment Act provided a tax holiday for the repatriation of foreign earnings. Advocates argued the Act would alleviate financial constraints by reducing the cost to U.S. multinationals of accessing internal capital. This paper shows that repatriations did not increase domestic...

We develop a positive model of multinational firm behavior and analyze a firm’s incentive to transfer an intellectual property (IP) right of uncertain value offshore ex ante, i.e. before its success or failure is realized. With an asymmetric treatment of losses in the home country, the...

This paper analyzes incentives of a multinational enterprise to manipulate an internal transfer price to take advantage of corporate-tax differences across countries under both monopoly and oligopoly. We examine "cost plus" and "comparable uncontrollable price" as two alternative implementations...