Drawing on the expertise of public international law and tax experts, this report explores the technical feasibility to develop a multilateral instrument to modify tax treaties so as to efficiently implement the tax treaty-related BEPS measures. The report concludes that such an instrument is...

The paper illustrates a discrepancy between the Act of Parliament and the narrative offered by the Australian Tax Office on the changes introduced since July 2009 with reference to Income Tax Assessment Act 1936 – S23AG. This pertains to the Double Tax Avoidance Agreements (DTAA) of which...

This paper employs unique data on export transactions and corporate tax returns of UK multinational firms and finds that firms manipulate their transfer prices to shift profits to lower-taxed destinations. It uncovers three new findings on tax-motivated transfer mispricing in real goods. First,...

This article provides a general overview of various privilege issues that frequently arise in the tax context, with a focus on international tax proceedings. Commonly disputed issues include the attorney-client privilege, work-product doctrine, accountant's privilege, tax practitioner privilege,...

This paper employs unique data on export transactions and corporate tax returns of UK multinational firms and finds that firms manipulate their transfer prices to shift profits to lower-taxed destinations. It uncovers three new findings on tax-motivated transfer mispricing in real goods. First,...

Under the BEPS Action 6 minimum standard on treaty shopping, members of the OECD/G20 Inclusive Framework on BEPS have committed to strengthen their tax treaties by implementing anti-abuse measures. This report reflects the outcome of the fifth peer review of the implementation of the BEPS Action...