Taxation of cross-border services has been identified as a high priority issue in the United Nations (UN) negotiations to establish a new global framework for tax. This paper analyses the defects of international tax rules as applied to services, and their exploitation by multinational...

In 2009, Japan began to exempt dividends paid by Japanese-owned foreign subsidiaries to their parent firms from home-country taxation. This tax reform switched Japan's corporate tax system to a territorial tax system that exempts foreign income from home-country taxation. In this paper, I...

Intangible assets constitute a major value-driver for multi-national enterprises (MNEs). This is even more so for companies that rely on valuable intangibles rather than physical assets to generate financial returns. Intangibles such as patents, design, trademarks (or brands) and copyrights are...