The 135 member countries in the OECD/G20 Inclusive Framework on BEPS are considering the adoption of a global minimum corporate income tax for taxing multinationals as part of the Pillar Two (GloBE) proposals for taxing the digital economy. This article provides a detailed analysis of the global...

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...

The 135 member countries in the OECD/G20 Inclusive Framework on BEPS are considering the adoption of a global minimum corporate income tax for taxing multinationals as part of the Pillar Two (GloBE) proposals for taxing the digital economy. This article provides a detailed analysis of the global...

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...

This study provides an interdisciplinary analysis of firm theory and international tax law, applied within a framework of hypothetical illustrations of prototypical multinational enterprises. The study finds that the construct and interpretation of different norms of international tax law...

UN Resolution 77/244, adopted by the General Assembly on 30 December 2022, reaffirms earlier commitments by the United Nations to improve international tax cooperation, fight illicit financial flows, and combat aggressive tax avoidance and evasion. The resolution asks that the Secretary-General...

Country-by-country reporting (CbCR) has become the global standard on corporate tax transparency within only 6 years after the release of the OECD BEPS reports in 2015. Recently, the European Union extended the scope of CbCR towards public disclosure of the reports. Despite the widespread...

Information technology has greatly changed the economy and intangible assets have become dominant value drivers of multinationals' business. Firm-specific intangibles challenge the time-honoured arm's length principle. The OECD's Action Plan on Base Erosion and Profit Shifting addresses this...