Hong Kong is not a tax haven, but is probably the only international financial centre that is not covered by a Double Tax Agreement (DTA). The relevant DTAs between the People's Republic of China (PRC) and the UK, the PRC and Australia or the PRC and the US do not apply to Hong Kong. This is...

This paper outlines and examines the taxation implications (primarily income tax) for residents of the United Kingdom (UK) and Australia also citizens and permanent residents of the United States (US) who are employed overseas. In addition to identifying specific taxation implications for...

This article proposes that U.S. international tax policy analysis must take into account non-tax regulation, which is generally disregarded in international tax policy analysis. Structural features of non-tax regulatory regimes will be shown to have significant implications for fundamental...

Many people — perhaps most — want to make money and lower their taxes, but few want to unabashedly break the law. These twin desires have led to a range of strategies, such as the use of “paper corporations” and offshore tax havens, that produce sizable profits with minimal costs. The...

Aggressive tax planning efforts of highly profitable multinational companies (Base Erosion and Profit Shifting (BEPS)) have become the subject of intense public debate in recent years. As a response, several international initiatives and parties have called for more transparency in financial...

Tax planning involving intangibles has become a major concern among governments, revenue authorities, media, the general public and international organizations. Multinational enterprises have been perceived to be able to shift profits by transferring and centralizing the ownership of intangibles...

This paper assesses the redistribution of foreign direct investments (FDI) and tax revenues among countries due to multinationals’ response to international differences in corporate tax systems. The paper briefly reviews the literature on the tax sensitivity of FDI and uses a consensus...

Since the turn of the current century, leading transnational organizations and academic scholarship have identified tax competition among countries as one of the scourges of the international tax regime. Both the EU and the OECD have warned that tax competition erodes the tax bases of Member...

This paper assesses how international tax planning affects real business investment by multinationals. Earlier studies have shown that corporate taxes reduce business investment. This paper shows that tax planning multinationals are less sensitive to corporate taxes than other firms in their...

I provide evidence on the group structures of multinationals and analyze to what extent these structures are tax efficient. While the corporate income tax can hardly be avoided if a subsidiary is active in a country, withholding taxes depend on the structure in which the subsidiary is embedded....