For decades, the OECD constituted an economic and political "club" of Western countries focused around the transatlantic axis. Today, it faces unprecedented challenges as the world economy shifts to the East and the South. In response, the OECD is undergoing meaningful reform: it is becoming...

The research evaluates Brazilian alignment to the OECD normative on the environment and climate change. It has three parts. The first describes the trajectory of the accession criteria, indicating how environment and climate change have come to influence the like-mindedness criterion. Given...

This background paper for the World Bank’s World Development Report 2011 discusses current financing arrangements for postconflict countries and fragile states, with a focus on official development assistance. In recent years a consensus has emerged that in these “difficult environments”...

Based on an analysis of 3,844 tax treaties, the Vienna Convention on the Law of Treaties and its Commentaries (VCLT), and case law of various domestic and international courts.The current orthodoxy maintains that courts are not required to compare all language texts of a plurilingual treaty but...

Out of all double tax treaties (DTTs) in force in 2012, around 41% are symmetric and 59% are asymmetric, i.e., they prescribe different dividend withholding tax rates (WTRs) depending on the foreign investor's ownership fraction. The paper investigates the reasons for this phenomenon, namely why...

This paper investigates the effects of double tax treaties (DTTs) on foreign direct investment (FDI) after controlling for their relevance in the presence of treaty shopping. DTTs cannot be considered a bilateral issue, but must be viewed as a network, since FDI can flow from home to host...

This is the tenth in a series of sixteen papers about the U.S extraterritorial tax system.The U.S. extraterritorial tax system violates multiple provisions of international human rights instruments that have been signed, or signed and ratified, by the United States. The rights in question...

This is the fourth in a series of sixteen papers about the U.S extraterritorial tax system.Millions of persons living overseas suffer under the U.S extraterritorial tax system. Many organizations and individuals have been and continue to work to change the system. But to date their efforts have...

In this installment of the Big Picture, Christians and Magalhães defend pillar 2’s undertaxed profits rule, arguing that it is supported by fundamental principles of international tax law and economic logic