Well before the OECD's BEPS Project began, there has been an ongoing debate over whether the Arm's Length Principle (ALP) provides an adequate basis for determining the allocation of income between associated enterprises in cross-border controlled transactions, and whether the principle should...

Schemes of residual profit allocation (RPA) tax multinationals by allocating their 'routine' profits to countries in which their activities take place and sharing their remaining 'residual' profit across countries on some formulaic basis. They have recently and rapidly come to prominence in...

This article considers multinational enterprises' capacity to deduct interest expenses in light of the implementation of Action 4 of the OECD/G20 Base Erosion and Profit Shifting Project and the OECD's current work on transfer pricing of financial transactions. It concludes that there has been a...

Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in selective federal states to evaluate the economic properties of formula apportionment relative...

Both older and recent literature on transfer pricing is not unified about the opinion whether optimal transfer price should be equal to marginal cost of supplying company and set by centralized decision (of vertically integrated multibusiness enterprise headquarters) or whether it should be set...

This paper elaborates on the emergence of so-called Advance Pricing Agreements (APA) in international taxation and corresponding APA programs in individual countries. It refers to how globalizing business processes trigger governance change on the nation state level regarding the identification...

With the advent of globalisation, the capital has highly become mobile with easy and no barrier flow between the nations. As a result of it now a single corporate taxpayer can deploy capital across multiple taxing jurisdictions. This incongruity slowly developed pique between domestic taxing...

Many studies have shown that the activities of multinational corporations are quite sensitive to differences in income tax rates across countries. In this paper I explore the interaction between multinational taxation and abatement activities under an international emissions permit trading...