International Taxation has a new GAAR: the “Principal Purpose Test” as laid down in Art.29(9) OECD Model Tax Convention (2017) and Art.7 Multilateral Instrument. While this new provision emphasises the relevance of the “purpose” of an arrangement or transaction, it does not refer...

In recent years, a move for destination-based taxes on business profits has become visible around the world. The most revolutionary and sophisticated model for international tax reform is the ‘Destination-Based Cash Flow Tax’ which is meant to replace the traditional corporate income tax and...

More and more countries offer tax benefits to attract wealthy individuals and sought-after experts.Under these regimes, mobile individuals are not subject to worldwide taxation on income and wealth any more. As many source countries waive their territorial taxing rights in order to attract...

International tax coordination has reached impressive results after the turn of the century. Multi-lateral agreements like the Common Reporting Standard or the BEPS Action Plan are clear signs of the willingness of a large number of states to cooperate in fiscal matters at a global scale....

In his David R. Tillinghast Lecture given at NYU in 1998, H. David Rosenbloom presented the tax world with a critical view as to the existence of an "international tax regime". Has the world changed since then? On the one hand, there is a strong move towards international tax coordination,...

This paper derives a government's optimal tax audit policy when taxpayers hold different beliefs about the likelihood of a tax audit. When audits are inexpensive, differences in perceived audit risk lead to stricter optimal auditing in equilibrium. If audits are relatively costly, heterogeneity...

We conduct an experiment to examine the role of retribution and deterrence in motivating third party punishment. In particular, we consider how the role of these two motives may differ according to whether a third party is a group or an individual. In a one-shot prisoner’s dilemma game with...

This paper examines the Clean Development Mechanism (CDM) of the Kyoto Protocol and its welfare implications for the countries engaging in it. It uses a simultaneous public good game, the public good being emission abatement, to asses the impact of the CDM on the public good provision...

This study compares contests with exogenous alliance formation under proportional sharing rules with contests among individual players in a laboratory setting. The standard equilibrium predictions are identical for all players because the proportional rule ensures the same payoff incentives for...

In a principal-agent model, we analyze the consequences of bonus taxes agents need to pay, limited deductibility of bonuses from company profits and a corporate income tax (CIT). We explore how these tax instruments affect managerial incentives and how they change the design of incentive...