This report is the third focused assessment of tax and development issues produced for G20 Finance Ministers and Central Bank Governors. It takes stock of progress by developing countries in the context of their engagement with the OECD/G20 Inclusive Framework, an international collaboration of...

The 2017 US tax legislation - widely referred to as the Tax Cut and Jobs Act (TCJA) - fundamentally transformed the US system of international taxation. It ostensibly ended worldwide taxation but introduced, for instance, a new tax on "Global Intangible Low-Taxed Income" (GILTI). This paper...

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...

In this paper, an outline of the consequences of the increased use of ICT on international corporate taxation, namely on the tax attributes and the scope of taxation, is given. It is argued that the concept of capital export neutrality shall prevail, as it is deemed to be the most appropriate to...

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...

President Obama has implemented a task force to study fundamental tax reform, and an honest debate about U.S. international tax policy is needed. The corporate inversion phenomenon provides an important insight into basic mistakes in U.S. international tax policy. The report examines those...