This position paper of the IBFD Academic Task Force (hereinafter IBFD Task Force) relates to the OECD's work on BEPS Action 1 and is devoted to withholding tax aspects. This position paper provides possible solutions to the challenges presented to the international tax regime by the digital...

This paper outlines the core issues of the introduction of a new PE nexus based on digital presence. It puts forward its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global economy. Our proposal of a new PE nexus based on digital...

If interpreted in a strict legal sense, beneficial ownership rules in tax treaties would have no effect on conduit companies because companies at law own their property and income beneficially. Conversely, a company can never own anything in a substantive sense because economically a company is...

Tax Risk Management requires seven steps to ensure complete compliance by taxpayers, in an international environment where tax authorities are becoming better equipped and organized in closing tax gaps. Part of the process of tax authorities is the formation of Large Tax Units that expect to...

The existence of different tax regimes and corporate rates of income tax between countries has given rise to international tax arbitrage and transfer pricing schemes. The objective of these schemes has been to minimize income tax expense and tax liabilities of multinational enterprises (MNEs)....

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...

This article examines the role that international comparisons play in current corporate tax reform discourse in the United States. Citing the need to make the U.S. corporate tax system more competitive, comparisons are frequently used to assess other jurisdictions' tax-competitiveness, and many...

This paper summarizes the key features of tax risk management and sets out the typical steps that should be followed. It follows a typical Six Sigma process in going about tax risk management. This paper discusses tax risk management, in particular, in the context of Section 404 of the U.S....

Globalization of the world economy enables companies and individuals to move across borders and seek new opportunities and business options in other countries. To do so persons may need to transfer residency or shift assets of permanent establishment. The adverse side of such a migration lies in...