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Fairness and Taxation in a Globalized World

Hemels, Sigrid - 2015

world this asks for action on a global scale. I will relate this to the Base Erosion and Profit Shifting (BEPS) project of …

Persistent link: https://www.econbiz.de/10013027445

Taxation as a Global Socio-Legal Phenomenon

Christians, Allison; Dean, Steven; Ring, Diane M.; … - 2010

areas of scholarship, including international relations theory, sovereignty theory, political philosophy, political economy …, and behavioral game theory, so as to begin to understand the changing pressures on taxation that are emerging as a result … of the increasingly complex relationship between states, markets, and people in a globalized world …

Persistent link: https://www.econbiz.de/10014220649

Addressing the transfer-pricing problem in an origin-basis X Tax

Bradford, David F. - 2003

In a previous paper I described how the tax design called the X Tax would facilitate an international tax system free of many of the complexities and avoidance opportunities plaguing the existing international tax regime and also have neutrality properties generally deemed desirable. A choice...

Persistent link: https://www.econbiz.de/10011508109

Addressing the Transfer-Pricing Problem in an Origin-Basis X Tax

Bradford, David F. - 2021

Persistent link: https://www.econbiz.de/10013319846

Interest Deduction, Corporate Groups and Tax Jurisdictions : A Hitchhiker's Guide to an Aspect of the BEPS Project

Masui, Yoshihiro - 2015

Persistent link: https://www.econbiz.de/10013032726

International Tax Neutrality : Revisited

Shaheen, Fadi - 2013

Viewing the development of the standard international tax neutrality discussion as being historically fairly limited because Musgrave's conclusions, rather than basic definitions, served as the undisputed baseline, in a previous article I reconsidered the classic international tax neutrality...

Persistent link: https://www.econbiz.de/10013083814

International Tax Neutrality : Reconsiderations

Shaheen, Fadi - 2013

Tax policy in general and international income tax policy in particular has long been a subject of discussion and argument by tax philosophers, economists, and lawyers. Theories have often been introduced to support the establishment of new tax systems, to justify existing ones, or to call for...

Persistent link: https://www.econbiz.de/10013083816

What Is Unilateralism in International Taxation?

Cui, Wei - 2020

The OECD recently emerged as the site of unprecedented, multilateral, and seemingly high-stakes negotiations about the future of international business income taxation. Judging by the political resources deployed in these negotiations, international tax has entered unchartered territory....

Persistent link: https://www.econbiz.de/10014094074

Taxation of the Digital Economy : Preliminary Analysis of OECD Pillar 1 Impact Assessment + KPMG Transfer Pricing Study of Amounts B & C (Presentation Slides)

Christians, Allison - 2020

A recent KPMG transfer pricing study posits fixed percentages for returns to marketing and distribution activities, a.k.a. Amounts B and C in OECD parlance. The study casts some light on the OECD's design for a new global tax allocation respecting the profits of certain digital economy firms. By...

Persistent link: https://www.econbiz.de/10012839986

OS ECJ-TF 1/2020 on the General Court Decisions of 24 September 2019 in The Netherlands v. Commission (Starbucks) (Joined Cases C-760/15 and T-636/16) and Luxembourg v. Commission...

Pinto Nogueira, João Félix; Garcia Prats, Francisco … - 2020

This article provides a comprehensive exame of the decisions of the EU General Court in the cases The Netherlands v. Commission (Starbucks) (Joined Cases C-760/15 and T-636/16) (hereinafter Starbucks NL) and Luxembourg v. Commission (Fiat Finance and Trade) (Joined Cases T-755/15 and T-759/15)...

Persistent link: https://www.econbiz.de/10014095439