The article argues that despite the fanfare around it, the outcome of the BEPS project is unlikely to be dramatic, at least in the short term. Beyond a period of increased legal uncertainty and aggressive enforcement by some countries, it expects little substantive change in tax treaties. The...

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...

Within a close system of legal rules, it is almost impossible to combat the abuse of offshore business and tax haven-related transactions. This is first because international business lacks even the fundamental sources of law. Secondly, even if international business were fully covered by...

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...

Before 2017, there were two major international movements going on at the same time: (1) the Trans-Pacific Partnership (TPP) Agreement; and (2) the Organization for Economic Cooperation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) Project. The movements presented a...

This paper outlines the core issues of the introduction of a new PE nexus based on digital presence. It puts forward its essential features and rethinks the foundations of the concept of sourcing for income tax purposes in the global economy. Our proposal of a new PE nexus based on digital...