The 2017 tax law made significant changes to the way the United States taxes multinational corporations on their cross-border income. The new legislation has, however, failed to solve old problems in the international system and also opened the door to new ones.The serious problems created, or...

Domestic anti-avoidance rules pose a special challenge because in several situations, they have to be given precedence over tax treaties in order to effectively prevent abuse. Therefore, the need arose for a consonant interpretation of tax treaties with these rules in order to prevent...

"While an increasingly large space in tax literature has been dedicated to the different methods of tax avoidance used by taxpayers to reduce their tax liability, not much has been said on how contracting states may make use of comparable tactics to increase tax revenue or extend economic...

The paper aims to identify the significant tax barriers to foreign direct investment (FDI) in Poland, in particular in the form of a permanent establishment (PE), in the context of new developments in international tax law. Due to the recommendations of the Base Erosion and Profit Shifting...

This paper explores the normative theory of international taxation by recasting it in parallel with the theory of international trade. It first sets out a definition of 'free trade taxation,' first in the global context and then in the unilateral context. It then evaluates against this standard...

This paper reviews quantitative studies of the impact of international tax rules on the financial and real behavior of multinational firms. The evidence, much of it recent, indicates that taxation significantly influences foreign direct investment, corporate borrowing, transfer pricing, dividend...

US Tax treaties have been regarded as self-executing since the first treaty (with France) was ratified in 1932. Rebecca Kysar has argued this raises a doubt on whether the treaties are constitutional, because tax treaties (like other treaties) are negotiated by the executive branch and ratified...

There is an ongoing extensive debate, virtually touching each jurisdiction, regarding the levy of taxes on digital services. Each country, especially the Source countries which have an extensive consumer base of digital services, is grappling with the increasing pressure to tax such services...