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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...
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Taxation of cross-border services has been identified as a high priority issue in the United Nations (UN) negotiations … are mainly hosts to MNEs. We analyse the restrictions on source taxation of services in tax treaties, particularly those … taxation of services, breaking with the residence-source dichotomy, and adopting formulary apportionment. This could be based …
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"Tax policy frequently targets the choices that women face in many aspects of their lives. Decisions regarding working away from home, having children, marrying, registering a partnership or cohabiting with a partner all entail tax consequences. The end of the twentieth century saw progress in...
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