This is the tenth in a series of sixteen papers about the U.S extraterritorial tax system.The U.S. extraterritorial tax system violates multiple provisions of international human rights instruments that have been signed, or signed and ratified, by the United States. The rights in question...

The international tax system faces substantial challenges with respect to taxing the profits of multinational companies in the digital economy. Both policymakers and taxpayers consider the determination of intra-company transfer prices the most pressing issue. This article analyses existing...

Considering a wide variety of international instruments and literature, this article will attempt to provide a comprehensive and consistent definition of the human right to development and its relationship to the human right to health and intellectual property. This article will also provide an...

Cross-border investments of states have rapidly increased over the last few years and are, more often than not, structured through special purpose investment funds or arrangements, known as sovereign wealth funds (SWFs). The total value of assets under the management of SWFs is currently...

Over time, the use of most favoured nation clauses has seen widespread adoption in double tax treaties, especially in those agreed with developing countries. The use of such clauses, however, does not appear to have been supported frequently by tax policies and/or careful ad hoc analysis, e.g....

The modernization of the EU VAT framework to address the booming development of B2C e-commerce has been one of the flagships of the European Commission 2016 "VAT Action Plan". With a view to reduce the risk of fraud in B2C e-commerce transactions involving goods, new rules imposing new...

Tax planning involving intangibles has become a major concern among governments, revenue authorities, media, the general public and international organizations. Multinational enterprises have been perceived to be able to shift profits by transferring and centralizing the ownership of intangibles...

The Inclusive Framework of the OECD/G20 currently discusses the internationally coordinated introduction of effective minimum taxes on multinational firm profits. This so-called GLOBE (global anti-base erosion) proposal is inspired by the GILTI and BEAT regimes of the 2017 US tax reform. It...