This paper proposes and evaluates alternative methods for addressing the tax treatment of interest expenses in a multijurisdictional setting. The differential deductibility of debt entailed by various current tax law provisions leads to potential distortions in the patterns of asset ownership...

The taxation of the digitalized economy is the single most important topic in international tax negotiations today. The OECD has devised a "Two Pillar solution" to the problem. Pillar One is focusing on a reallocation of taxing rights to market jurisdictions, which are largely expected to be...

1. Introduction -- 2. International Taxation and Transactional Models -- 3. Business Strategy and Transactional Models -- 4. Direct Business -- 5. Merchandize Business -- 6. Agency Business -- 7. Conclusion.