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Residual profit allocation by income : a paper of the Oxford International Tax Group chaired by Michael P. Devereux
Devereux, Michael P.; Auerbach, Alan J.; Oosterhuis, Paul; … - 2019
Persistent link: https://www.econbiz.de/10013347701
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Transfer pricing and sourcing strategies for multinational firms
Shunko, Masha; Debo, Laurens; Gavirneni, Srinagesh - In: Production and operations management : an international … 23 (2014) 12, pp. 2043-2057
Persistent link: https://www.econbiz.de/10010479108
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Impact of a minimum tax rate under the Pillar Two solution on small island developing states
Sharma, Kuldeep - 2022
The Research Paper commences with an overview of Pillar One and Pillar Two followed by detailed discussions on salient provisions of Pillar Two. Pillar Two is envisaged to have a widespread impact on Small Island Developing States (SIDS) which are a distinct group of 38 United Nations (UN)...
Persistent link: https://www.econbiz.de/10013393654
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Tax havens and cross-border licensing with transfer pricing regulation
Choi, Jay Pil; Ishikawa, Jota; Okoshi, Hirofumi - In: International tax and public finance 31 (2024) 2, pp. 333-366
Persistent link: https://www.econbiz.de/10015056369
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Transfer pricing and intangibles : subject I ; [61st congress of the International Fiscal Association, Kyoto 2007]
Miyatake, Toshio (contributor) - 2007
Persistent link: https://www.econbiz.de/10003484125
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Transfer pricing and location choice of intangibles : spillover and tax avoidance through profit shifting
Reineke, Rebecca; Weiskirchner-Merten, Katrin - 2018
Large multinational companies are regularly suspected of using transfer pricing of intangibles to shift profits from … high- to low-tax jurisdictions. We study the optimal transfer prices while endogenizing the location choice of intangibles … and considering spillovers. In line with the initial intuition, we find that multinationals locate their intangibles in low …
Persistent link: https://www.econbiz.de/10011975867
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A tough call? : comparing tax revenues to be raised by developing countries from the Amount A and the UN Model Treaty Article 12B regimes
Starkov, Vladimir; Jin, Alexis - 2022
In this research paper, we attempt to estimate the tax revenues to be gained (or lost) by the South Centre and African Union's Member States under the Amount A and Article 12B regimes. Our analysis relied on sources of information available to private sector researchers but did not involve...
Persistent link: https://www.econbiz.de/10013257990
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Two Pillar solution for taxing the digitalized economy : policy implications and guidance for the Global South
Ovonji-Odida, Irene; Grondona, Veronica; Chowdhary, … - 2022
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...
Persistent link: https://www.econbiz.de/10013337674
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Evaluating the impact of Pillars One and Two
Tandon, Suranjali; Rao, Chetan - 2022
The proposed OECD Pillar One and Two reforms mark a significant shift in the way large multinational enterprises are taxed on their global incomes. However, while considering the reform at the proposed scale tax administrators must be able to compare the revenue gains with alternatives. This...
Persistent link: https://www.econbiz.de/10013393628
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Chapter 28 International taxation
Gordon, Roger H.; Hines, James R. - In: Handbook of public economics : volume 4, (pp. 1935-1995). 2002
The integration of world capital markets carries important implications for the design and impact of tax policies. This …
Persistent link: https://www.econbiz.de/10014024861