The 2017 US tax legislation - widely referred to as the Tax Cut and Jobs Act (TCJA) - fundamentally transformed the US system of international taxation. It ostensibly ended worldwide taxation but introduced, for instance, a new tax on "Global Intangible Low-Taxed Income" (GILTI). This paper...

The international agreement on a corporate minimum tax is a milestone in global corporate tax arrangements. The minimum tax disturbs the equivalence between otherwise equivalent forms of efficient economic rent taxation: cash-flow tax and allowance for corporate equity. The marginal effective...

Tax administration plays a crucial role In determining a country’s real (or effective) tax system. Unfortunately, tax administrations in many countries do not function optimally and distort the intention of tax laws. In order for taxation to have its intended effect on the allocation of...

One of the most striking tax developments in recent years, and one that continues to attract considerable attention, is the adoption by several countries of a form of ""flat tax."" Discussion of these quite radical reforms has been marked, however, more by assertion and rhetoric than by analysis...

In this paper, an outline of the consequences of the increased use of ICT on international corporate taxation, namely on the tax attributes and the scope of taxation, is given. It is argued that the concept of capital export neutrality shall prevail, as it is deemed to be the most appropriate to...

Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in selective federal states to evaluate the economic properties of formula apportionment relative...