Based on an analysis of 3,844 tax treaties, the Vienna Convention on the Law of Treaties and its Commentaries (VCLT), and case law of various domestic and international courts.The current orthodoxy maintains that courts are not required to compare all language texts of a plurilingual treaty but...

This paper looks into the investment behavior of multinational firms with respect to their locked-out foreign earnings. The focus is on multinational firms subject to credit and deferral home-country taxation such as that of the United States. “Locked-out earnings” refers to the earnings of...

This article discusses the taxation law of corporate groups based on the branch reports from 30 jurisdictions. Its major findings are: -Tax planning often does not work. -A legislative framework is essential for a stable tax environment. -Group taxation regimes in more EU jurisdictions...

This paper evaluates the Multilateral Convention to implement Pillar I Amount A, released by the OECD in October 2023, and the alternative proposal of Art. 12B for tax treaties suggested by the UN, with a particular emphasis on the perspective of developing countries. We conduct a comparative...