This paper constructs and analyzes a rudimentary game-theoretic model to better understand the policy choice between a global minimum tax regime that operates country-by-country and one that operates based on MNEs’ global average tax rates. The paper’s findings run counter to the consensus...

UN Resolution 77/244, adopted by the General Assembly on 30 December 2022, reaffirms earlier commitments by the United Nations to improve international tax cooperation, fight illicit financial flows, and combat aggressive tax avoidance and evasion. The resolution asks that the Secretary-General...

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...

African nations must adopt policies to counter corporate tax avoidance, especially in a digital economy. The Corporate Tax Haven Index of 2019, developed by the Tax Justice Network, is the first systematic, unpoliticised and verifiable measure of how jurisdictions facilitate abusive tax activity...

The OECD base erosion and profit-shifting project (BEPS) presents a unique opportunity for the international tax regime. BEPS is taking on an immense challenge, with 15 separate action items on such issues as the digital economy, hybrid mismatches, treaty abuse, intangibles transfer pricing, and...

This article examines an influential set of articles, written by Professor John Tiley in the late 1980s, about anti-avoidance doctrines developed by US courts. The trilogy of articles was written for a British audience, as part of Tiley's efforts to resist importation of US doctrines...

This book chapter discusses the background to the UK General Anti-Avoidance Rule, analyses the wording of the legislation and looks at its relationship with double taxation treaties and EU and OECD developments

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...