The OECD Programme of Work on the tax challenges arising from the digitalization of the economy comprises a so-called GloBE (Global Base Erosion) or Pillar Two proposal, consisting of a series of measures aimed at establishing a floor to tax competition by achieving minimum taxation of the...

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 paper considers New Zealand's hybrid tax credit system consisting principally of a credit system combined with exemption features in respect of certain classes of income, both of which aim to provide relief to minimise the impact of foreign income being taxed in a foreign jurisdiction as...

This paper considers the treatment of multinational business in the system known as an X Tax. The focus is on the choice between origin and destination treatments of transborder transactions. The destination-principle approach sidesteps the transferpricing problem. It remains in the...

This paper proposes and evaluates alternative methods for addressing the tax treatment of interest expenses in a multijurisdictional setting. The differential deductibility of debt entailed by various current tax law provisions leads to potential distortions in the patterns of asset ownership...

This work undertakes a comprehensive analysis of the U.S. state experience under formulary apportionment of corporate income. While formulary apportionment eliminates the possibility of shifting income across states through accounting strategies that manipulate where income is booked, it may...

The integration of world capital markets carries important implications for the design and impact of tax policies. This paper evaluates research findings on international taxation, drawing attention to connections and inconsistencies between theoretical and empirical observations. Diamond and...

The theory of corporate tax incidence suggests that corporate taxes are more likely to harm labor in a globally integrated economy. However, a review of the prior empirical work in this area fails to reveal persuasive empirical evidence of adverse effects on labor, since these studies have...

We investigate the relation between international taxation and the organizational form of foreign direct investment (‘FDI’). Using micro-level data on inbound FDI relations in Germany, we find that a higher tax burden on income earned in a corporate subsidiary increases the probability that...

With opening of the economy in 1991 and subsequent removal of regulatory and trade barriers, India became an attractive investment (Foreign Direct Investment-FDI) destination. A large number of multinationals have established operations in India to utilise the services of available skilled...