This paper presents a rationale of why and under what economic environment the corporate income tax should exist, in particular, as a form of double taxation. In this sense, we suggest the tax code similar to those in the real world, however, ours turns out to be informationally much more...

This article examines the potential conflict between thin capitalization rules and the OECD Model article on non-discrimination using the New Zealand regime exempli gratia. It is discriminatory to impose a higher tax burden on an enterprise funded with foreign capital. Yet that is the basis for...

This article begins by examining the relationship between thin capitalisation rules and double tax treaties. After examining the potential for a fundamental conflict in this area it looks at the OECD's attempts to resolve the problem (in section 2). In sections 3 and 4, the article examines the...

This paper examines the impact of thin capitalization rules that limit the tax deductibility of interest on the capital structure of the foreign affiliates of US multinationals. We construct a new data set on thin capitalization rules in 54 countries for the period 1982-2004. Using confidential...

This paper examines the impact of thin capitalization rules that limit the tax deductibility of interest on the capital structure of the foreign affiliates of US multinationals. We construct a new data set on thin capitalization rules in 54 countries for the period 1982-2004. Using confidential...

In October 2015, the OECD made a best practice recommendation in Action 4 of its BEPS project, suggesting a Fixed Ratio Rule in place of thin capitalisation rules. This review was almost 3 decades in the making, with the most recent OECD report on thin capitalisation rules published in 1986,...