This study was drafted as the EU topical report for IFA's general report on the topic reconstructing the treaty network and deals with the intersection of three areas: i) European Union law; ii) the OECD's Base Erosion and Profit Shifting project (BEPS) and its implementation, and; iii) member...

On January 1, 1994, Canada, the United States and Mexico formed the North American Free Trade Agreement (NAFTA) to promote their economic interests by lowering barriers to international trade and investment. A concern exists that national tax differences harm or inhibit cross-border investment...

We investigate the outcome of bilateral tax competition by analyzing Double Tax Treaties (DTT). DTTs are the crucial means of splitting a tax base between two countries. Yet, there are only few empirical results on the textual design of DTTs. We develop a novel approach to quantitatively analyze...

This paper explores empirically whether and how FDI is affected if multinationals' home countries change taxation of foreign earnings by switching from worldwide to territorial taxation. Our analysis employs data for German inbound FDI based on the ultimate investing country concept. We use a...

This paper investigates the transfer pricing risk awareness of multinational firms using cross-sectional data of more than 350 firms located in 24 countries and classified in 12 industries. Moving beyond the sole tax optimization motives of multinational firms, we extend the existing literature...

In intra‐group finance hybrid instruments allow for tailor‐made form of finance. Hence hybrid finance is often used for international tax planning in multinational groups.Due to a lack of international tax harmonization or tax coordination qualification conflict can arise. A specific hybrid...

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...

Traditionally, countries impose their corporation tax on an entity-by-entity rather than a group-wide basis. As the taxability of entities, tax bases, and tax rates vary from one country to another, these differences give rise to mismatches, leading to double taxation, but also to non-or almost...

The current system of international taxation does not result in a fair distribution of the tax base between countries in a digital environment violating the principle of taxation in accordance with the added value created in the particular country. In the absence of international consensus,...

The aim of the paper is to highlight, at a theoretical level, the effects of globalization on fiscal policy, as well as the issue of profit shifting at OECD level, given that, although substantial progress has been made internationally in multilateral fiscal coordination, it remains at a...