The aim of the paper is to highlight, at a theoretical level, the effects of globalization on fiscal policy, as well as the issue of profit shifting at OECD level, given that, although substantial progress has been made internationally in multilateral fiscal coordination, it remains at a...

The 135 member countries in the OECD/G20 Inclusive Framework on BEPS are considering the adoption of a global minimum corporate income tax for taxing multinationals as part of the Pillar Two (GloBE) proposals for taxing the digital economy. This article provides a detailed analysis of the global...

Among the ways in which multinational enterprises (MNEs) can shift profits from one jurisdiction to another in order to minimize taxes, one of the most simple and widely-employed involves the payment of interest to related parties and third parties. For these reasons, it is not surprising that...

The OECD's BEPS project mandated that transfer pricing outcomes under the arm's-length standard should be aligned with value creation. In the digital economy, new business models are challenging transfer pricing practitioners on how best to apply the value creation approach. In a two-part series...

This study aims to provide feedback to the OECD on its Public Consultation, launched on 8 November 2019, on the specific matters of the Global Anti-Base Erosion (GloBE) Proposal, also known as Pillar Two of the BEPS 2.0 Project, as included in the Public Consultation Document (The "Public...

National policymakers addressing international corporate taxation must balance a revenue objective with a need to maintain and augment national economic resources and assist the success of national firms. International collaboration after the First World War established a set of principles that...

The OECD Base Erosion Profit Shifting (BEPS) Initiative as well as the current fairness oriented public discussion regarding the taxation of digital business models highlight the importance and complexity of the arm's length principle. In a theoretical model of an internationally fragmented...

The Unified Approach issued by the OECD Secretariat on Oct 9, 2019, is the OECD's most recent attempt to find international consensus on BEPS Action Item 1, “Taxing the Digital Economy.” Our assessment is that the Pillar One proposals in the Unified Approach suffer from several defects, the...

Much work has been done by international organizations, tax scholars around the world and business experts on the future shape of the taxation of the digitalized economy. Starting from the assumption that any “ring-fencing” of the digitalized economy should be avoided, it is far from easy to...