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Interest Deductibility : Implementation of BEPS Action 4 and the Future of Transfer Pricing of Intragroup Finance

Burnett, Chloe - 2019

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...

Persistent link: https://www.econbiz.de/10012862264

Inequality and Taxation of Multinational Corporate Groups

Schmiel, Ute - 2020

The present paper deals with the question how to tax multinational corporate groups in order to reduce inequality. Since inequality is abstract, it is necessary to interpret it, which implies referring to ethical concepts and theories. Ethical concepts argue that companies should generally be...

Persistent link: https://www.econbiz.de/10012825103

When Global Tax Reform Meets International Trade Rules : An Inquiry into the Intersection of the GATS and the BEPS Package

Zhang, Weiwei - 2017

Persistent link: https://www.econbiz.de/10012959338

Multinational Efforts to Limit Intellectual Property Income Shifting : The OECD's Base Erosion and Profit Shifting (BEPS) Project

Maine, Jeffrey A. - 2019

Before 2017, there were two major international movements going on at the same time: (1) the Trans-Pacific Partnership (TPP) Agreement; and (2) the Organization for Economic Cooperation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) Project. The movements presented a...

Persistent link: https://www.econbiz.de/10014103137

Reply to Scherer/Schmiel : Ethical and Legal Responsibility of MNCs (NTJ 2021, 32-46) - Why the Arm’s Length Principle Yet Leads to Fair Taxation

Eglmaier, Silvia - 2022

In their article (NTJ 2021, 32-46), Scherer/Schmiel (1) postulate the introduction of a taxation of corporate groups on the basis of ethical responsibility according to a political-cultural market theory. The background to this is that corporate groups might apply tax avoidance or pay too little...

Persistent link: https://www.econbiz.de/10014244296

For a Better GLOBE. METR : A Minimum Effective Tax Rate for Multinationals

Picciotto, Sol; Faccio, Tommaso; Kadet, Jeffery M.; … - 2021

An initiative is needed to break the logjam in the international negotiations to reform taxation of multinational enterprises (MNEs). The primary agreed goal of the project on Base Erosion and Profit Shifting (BEPS) was to better align MNEs’ taxable profits with the location of real economic...

Persistent link: https://www.econbiz.de/10013237439

For a Better GLOBE : A Minimum Effective Tax Rate for Multinationals

Kadet, Jeffery M.; Cobham, Alex; Faccio, Tommaso; … - 2021

Persistent link: https://www.econbiz.de/10013238289

Automatic Information Exchange versus the Withholding Tax Regime Globalization and Increasing Sovereignty Conflicts in International Taxation

Cavelti, Luzius U. - 2017

, the increasing influence of globalization and digitalization on domestic tax systems has made improved international …

Persistent link: https://www.econbiz.de/10012973719

Re-Imagining Offshore Finance : Market-Dominant Small Jurisdictions in a Globalizing Financial World

Bruner, Christopher M. - 2016

Small jurisdictions have become significant players in cross-border corporate and financial services. Their nature, legal status, and market roles, however, remain under-theorized. Lacking a sufficiently nuanced framework to describe their functions in cross-border finance - and the peculiar...

Persistent link: https://www.econbiz.de/10013007073

Tax Activists and the Global Movement for Development Through Transparency

Christians, Allison - 2016

Activists around the world seek to expose a global system that fails to tax multinationals adequately and thus deprives … governments of needed revenues, with profound effects for development in the world's poorest nations. These tax activists have … sparked a global movement, with groups all over the world seeking progress for development in poor countries by demanding …

Persistent link: https://www.econbiz.de/10013008182