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...

Since the early 1990s the issue of fiscal transparency has attracted increasing attention from international institutions, governments, and NGO's concerned with budgets and fiscal policy reform. This Article offers a critical analysis of the meaning and purposes of fiscal transparency in light...

Free zones have become increasingly popular as trade promotion policy instruments in developing countries. This article explains how the obligations in the WTO Agreement on Subsidies and Countervailing Measures apply to free zones. An analysis of the most common requirements for companies...

Viewing the development of the standard international tax neutrality discussion as being historically fairly limited because Musgrave's conclusions, rather than basic definitions, served as the undisputed baseline, in a previous article I reconsidered the classic international tax neutrality...

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...

Money laundering has become a phenomenon of financial market regulation. The obligation to identify the ultimate beneficiary, or the beneficiary owner, which need not be entirely synonymous terms, has been the focus for both national authorities and international organizations. However, such...

This paper provides a practical overview and normative analysis of international tax planning ideas for entities who are establishing or restructuring their business affairs. In particular, in an international financial hub, such as Hong Kong, taxation advisors and lawyers need to be...

We present four important dimensions to international tax policy from a tax-systems perspective, stressing that non-rate/base tax policies can have different cross-jurisdictional spillover effects than changes in tax rates. The dimensions are the allocation of global income among taxing...

The last three decades have been marked by a battle with money laundering, tax evasion, and even though not strictly illegal, but no less harmful, tax avoidance after the boom in those legal and accountancy services back in the 1980s. The methods that national, international, and supranational...