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decision-making authority in relation to taxation shifts from the national to the international level, the more its legitimacy … is questioned. The purpose of this article is to examine whether the OECD indeed lacks legitimacy and, if so, what could … be done to overcome such a legitimacy deficit. The article starts by analysing in more detail the role that the OECD has …
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Fundamentals of the Taxation of Permanent Establishments -- The Attribution of Profits to Permanent Establishments -- Digitalisation of the Economy and Its Implications for the PE Concept -- Adapting the International Corporate Tax System to the Digitalisation of the Economy.
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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...
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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...
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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