The Unified Approach issued by the OECD Secretariat on Oct 9, 2019, is the OECD's most recent attempt to find international consensus on BEPS Action Item 1, “Taxing the Digital Economy.” Our assessment is that the Pillar One proposals in the Unified Approach suffer from several defects, the...

The Internal Revenue Service (“IRS”) and the Treasury Department require the reporting of detailed information concerning a broad array of foreign transactions. These reports and forms enable the IRS to obtain information that is useful for tax, regulatory and investigative purposes. The...

Inherent features of any business tax are the imposition of relatively higher compliance costs on small businesses and higher administrative costs faced by tax authorities in respect of these firms, allied with low net tax revenue collected from the sector. A common response in jurisdictions...

Intangible assets constitute a major value-driver for multi-national enterprises (MNEs). This is even more so for companies that rely on valuable intangibles rather than physical assets to generate financial returns. Intangibles such as patents, design, trademarks (or brands) and copyrights are...

The current system of international taxation does not result in a fair distribution of the tax base between countries in a digital environment violating the principle of taxation in accordance with the added value created in the particular country. In the absence of international consensus,...

This study investigates the influence of three interest groups—businesses, the tax profession, and civil society—on tax rules in the context of the Organization for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) project. Our study is important as prior...