Shifting intellectual property (IP) rights across jurisdictions is a well-known strategy of multinationals to reduce corporate income taxation. We investigate the extent to which the flows of remunerations for the use of IP rights are affected by differences in corporate income and withholding...

We study the choice between source-based and destination-based corporate taxes in a two-country model, allowing multinational firms to use transfer pricing to allocate profits across tax jurisdictions. We show that source-based taxation is a Nash equilibrium for tax revenue maximizing...

The OECD recently emerged as the site of unprecedented, multilateral, and seemingly high-stakes negotiations about the future of international business income taxation. Judging by the political resources deployed in these negotiations, international tax has entered unchartered territory....

Recent years have seen a dramatic increase in the attention given to abusive tax schemes that take advantage of bilateral tax treaties. The ensuing discourse tends to view potential responses to treaty abuses as a hierarchical set of options, gradually escalating, in which treaty termination is...

If interpreted in a strict legal sense, beneficial ownership rules in tax treaties would have no effect on conduit companies because companies at law own their property and income beneficially. Conversely, a company can never own anything in a substantive sense because economically a company is...

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...