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Interest Deductibility : Implementation of BEPS Action 4 and the Future of Transfer Pricing of Intragroup Finance

Burnett, Chloe - 2019

This article considers multinational enterprises' capacity to deduct interest expenses in light of the implementation of Action 4 of the OECD/G20 Base Erosion and Profit Shifting Project and the OECD's current work on transfer pricing of financial transactions. It concludes that there has been a...

Persistent link: https://www.econbiz.de/10012862264

Transfer pricing and related party transactions : a bibliometric analysis

Capatina-Verdes, Neli - In: Central European economic journal 9 (2022) 56, pp. 237-253

In order to create complex business structures and to obtain economic benefits, multinational companies have given rise to transfer pricing. Due to their importance, it has been possible to expand international trade to a higher level. This study focuses on the issue of transfer pricing and...

Persistent link: https://www.econbiz.de/10013502207

Transfer Pricing Issues of BEPS in the Light of EU Law

Schoen, Wolfgang - 2015

One of the aims of the BEPS Action Plan is to reduce existing leeway for multinational enterprises to shift profits by exploiting transfer pricing rules. Profit allocation is meant to be aligned with “real activity” and “value creation.” This article is devoted to the question of whether...

Persistent link: https://www.econbiz.de/10013015843

Blueprints for a new PE nexus to tax business income in the era of the digital economy

Hongler, Peter; Pistone, Pasquale - 2015

light of a new dimension for the benefit theory.Our work directly relates to Action 1 of the OECD/G20 BEPS Project. However …

Persistent link: https://www.econbiz.de/10011334067

Country-by-Country Over-Reporting? National Sovereignty, International Tax Transparency, and the Inclusive Framework on BEPS

Tavares, Romero J.S. - 2017

Persistent link: https://www.econbiz.de/10012954602

The Offshore Tax Enforcement Dragnet

Oei, Shu-Yi - 2018

Taxpayers who hide assets abroad to evade taxes present a serious enforcement challenge for the United States. In response, the United States has developed a family of initiatives that punish and rehabilitate non-compliant taxpayers, raise revenues, and require widespread reporting of offshore...

Persistent link: https://www.econbiz.de/10012934338

Spillovers and Tax Sovereignty

Christians, Allison - 2017

Some countries are undertaking, and others considering, self-examination rules to detect whether proposed tax reforms might have a negative impact on tax policy or economic outcomes in less affluent countries. The impetus for this kind of analysis is a loosely articulated idea that states may...

Persistent link: https://www.econbiz.de/10012947702

Historic, Comparative and Evolutionary Analysis of Tax Systems

Christians, Allison - 2010

Tax reform is a constant process in most nations as governments continuously revisit their tax regimes in response to economic, social, and political forces. Domestic legislative processes are the most obvious source of change in the tax system in any independent nation, but international...

Persistent link: https://www.econbiz.de/10014191360

Avoidance, Evasion, and Taxpayer Morality

Christians, Allison - 2018

In popular discourse, tax evasion by wealthy individuals is conflated with tax avoidance by multinational corporations to tell a single story about tax dodging and its negative impact on society. But conflating avoidance and evasion muddies the tax policy waters in important ways by turning...

Persistent link: https://www.econbiz.de/10014147082

Taxing Cross-Border M&A in a Globalizing World

Brauner, Yariv - 2015

M&A play a major role in the materialization of globalization, but it is just one of several challenges that … globalization poses to international tax policy, all of which share two basic tensions that may have been present in the past, but … have been significantly exacerbated in importance by globalization: the revenue flight dilemma and the multinational …

Persistent link: https://www.econbiz.de/10014084637