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State Strategic Responses to the GloBE Rules

06 Feb 2023

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Heydon Wardell-Burrus

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State Strategic Responses to the GloBE Rules

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OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors (G20 Brazil, October 2024)

24 Oct 2024

Capital Flows and Wealth Distribution in a Global Economy with Asymmetric Countries

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Update on the Revenue Effects of GILTI and FDII, 2026 Rate Changes, and Proposed Policy Reforms

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The Implications of Treaty Restrictions of Taxing Rights on Services, Especially for Developing Countries

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10 Years of Banking Union’s Case-Law: How Did European Courts Shape Supervision and Resolution Practice in the Banking Union?

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Tax Policy Reforms 2024: OECD and Selected Partner Economies

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Digital Economy & Taxation: Challenges and Opportunities In Nigeria

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Comment Letter on the June 2024 Administrative Guidance

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Corporate Inversions and the Global Ultimate Owner: Challenges in International Business Research

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How Kamala Harris's Tax Hike Could Affect Business Growth

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Country-by-Country Reporting – Compilation of 2024 Peer Review Reports

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The EU's Uncoordinated Approach to Tax Avoidance and Tax Abuse in Relation to 'Uncooperative' Tax Jurisdictions

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Reimagining Tax Treaty Dispute Resolution; beyond MAP and Arbitration

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Cross-Border Taxation in a World of Abundant Capital

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International Compliance Assurance Programme (ICAP) Outcome Letter Template

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The Future of European Competitiveness – A Competitiveness Strategy for Europe

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The Subject to Tax Rule: A Comparison of The OECD and UN Versions

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Tokenization: Unlocking Developing Countries Wealth

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FTC Proposals, Part II: TCJA White Paper

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An Investigation of the Array of Domestic and Foreign Tax Haven Location Decisions for U.S. Multinational Firms

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Why the U.N. Must Put AI and Data on the Tax Agenda

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International Tax Scholarship and International Tax Activism

22 Aug 2024

FTC Proposals, Part I: Creditable Foreign Taxes

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Climate Policies and External Adjustment

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A New Governance Framework in Cross-Border Tax Policymaking

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Chair’s Proposal for Draft Terms of Reference for a United Nations Framework Convention on International Tax Cooperation

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Taxation of the Digital Economy: An Appraisal of the Effectiveness of the OECD Tax Deal on Low-and-Middle Income Countries

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Globalization, Erosion of Tax Base, and the Revenue Potential of Developing Asia's Foreign Exchange Reserve Build-Up

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Potential Changes to Section 367 and the Associated Treasury Regulations

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A Global Perspective on the Incidence of Monopoly Distortions

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International Tax Reform and the Biden-Harris Tax Pledge

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Subpart F and GILTI Recommendations

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Taxation of Foreign-Derived Intangible Income

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Power and Expertise in Global Tax Governance

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India’s Pillar Two Pledge May Have Limited Impact, Experts Warn.

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U.S. Ownership of Foreign Stock: Dividends and Gains on Sale

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U.S. Subsidiaries of Foreign-Based MNEs — BEAT and Section 163

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Interpreting Tax Treaties: The Importance of Post-Treaty Commentary to the OECD Model Tax Convention for Achieving Uniformity and Ensuring the Success of the New International Tax Order

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Mulilateral Tax Reform

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The Taxation of Robots and Its Global Challenges

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Revised Draft Terms of Reference for a United Nations Framework Convention on International Tax Cooperation

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ICAP Documentation Requirements: Selection Documentation Package Templates

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The EU as a Tax Harmonisation Catalyser – Triumphs and Challenges within an Asymmetric Cooperation Model

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Considerations Relating to CFC Stock Ownership and Allocation of Subpart F Income

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Considerations for Reforming the U.S. Source of Income Rules

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The Global Minimum Tax and Special Economic Zones

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International Tax and International Law Revisited

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Can Investment Treaties Defeat Pillar 2

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Corporate Tax Statistics

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Principles Justifying the Reallocation of Taxing Rights to Market Jurisdictions: Do We Need Them?

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Considerations for Reforming the U.S. Transfer Pricing Rules

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Qualified Status under the Global Minimum Tax: Questions and Answers

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Tax Challenges Arising from the Digitalisation of the Economy –Administrative Guidance on the Global AntiBase Erosion Model Rules (Pillar Two), June 2024

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Broadening the Gains from Generative AI: The Role of Fiscal Policies

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A Toss Up? Comparing Tax Revenues from the Amount A and Digital Service Tax Regimes for Developing Countries

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Zero Draft Terms of Reference for a United Nations Framework Convention on International Tax Cooperation

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International Compliance Assurance Programme (ICAP) Frequently Asked Questions

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A Scrap Game: Impacts of the EU Carbon Border Adjustment Mechanism

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2024 Progress Report on Tax Co-operation for the 21st Century

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Taxation and the Realisation of Socioeconomic Rights in Africa: What Is the Role of International Cooperation?

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The Role of the Investor Motive in the Effectiveness of Tax Incentives: Evidence for FDI Location in Indonesia

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Tax Hybridity and the Globalization of Taxation: Convergence, Borrowing, Culture

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A Global Minimum Tax for Large Firms Only: Implications for Tax Competition

26 Apr 2024

Detecting Cross-Border Transaction Patterns Using Machine Learning: The Case of Indonesia

25 Apr 2024

Tax Challenges Arising from the Digitalisation of the Economy – Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2023)

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Profit-Shifting Elasticities, Channels, and the Role of Tax Havens: Evidence from Micro-Level Data

22 Apr 2024

Import Competition and U.S. Sentiment Toward China

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The Design of a UN Framework Convention on International Tax Cooperation

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Taxation of Autonomous Artificial Intelligence: Socially Sustainable Expansion of Automation and Impacts on International Tax

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Tax Treaties and Denizenship Based Tax Systems

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Design and Consequences of CFC and GILTI Rules: A Review and Potential Lessons for the Global Minimum Tax

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Tax Treaties and Income Shifting

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The OECD/G20 Pillar 1 and Digital Services Taxes: A Comparison

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The Digital Economy, Global Tax Reforms and Developing Countries – An Evaluation of Pillar I and Art. 12B UN Model

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Broader Border Taxes: A New Option for European Union Budget Resources

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Efficient Economic Rent Taxation Under a Global Minimum Corporate Tax

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Promoting Inclusive and Effective Tax Cooperation at the United Nations

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Case Law Trend: Withholding Taxation Under the Fundamental Freedoms

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Location, Financial and Real Effects of CFC Rules after the ATAD Implementation in the EU

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Tax Transparency in Africa 2024: Africa Initiative Progress Report

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2024 European Elections Manifesto: The Accountancy Profession’s Priorities for the EU Mandate 2024 - 2029

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Background and Analysis of the Taxation of Multinational Enterprises and the Potential Reallocation of Taxing Rights Under the OECD’s Pillar One

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Business model digitalization, competition, and tax savings

01 Mar 2024

International Cooperation on Tax Matters at the United Nations: A Turning Point in History?

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Understanding the Impact of OECD BEPS Actions on Double Tax Treaties

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The Untold Tale of a Tax Rulings Haven

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Exchange of Information, Tax Confidentiality, Privacy and Data Protection from an EU Perspective

28 Feb 2024

Analysis of Developments in EU Capital Flows in the Global Context (2023)

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Pillar One - Amount B

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Cryptocurrency Investments and Taxation: Analyzing Global Responses by Tax Authorities

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The Proposal for a Council Directive on Transfer Pricing: An Assessment

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Deterrence and Displacement in Offshore Trade: Evidence from the Panama Papers Leak

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The consequences of the 2017 US international tax reform: a survey of the evidence

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Whither LOB?

02 Feb 2024

Dual-residency of Companies and EU Law: Accessing Corporate Tax Directives’ Benefits After the 2017 OECD Model Tax Convention Changes in the Dual-residency Tie-breaker for Companies

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Tax It Before Exit: Exit Taxation and Greenfield Investments

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The UTPR and the Treaties

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The Tax Attractiveness of EU Locations for corporate Investments: A Stocktaking of past Developments and recent Reforms

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The Global Minimum Tax and the taxation of MNE profit

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Taxing Digital Platforms

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Frequently Asked Questions on Pillar 2 Directive

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Are Consumers Paying the Bill? How International Tax Competition Affects Consumption Taxation

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Macroeconomic Policy Questions: Promotion of Inclusive and Effective International Cooperation on Tax Matters at the United Nations

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Financial Constraints and Tax Planning: International Evidence

20 Dec 2023

Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), December 2023

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Destination Taxation of Corporate Income and the Emerging Implications

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Tax In History: CFCs and Tax Treaties: Historical Elements for the IIR Debate

30 Nov 2023

Directions for International Tax Policy, A Response to Hanna and Wilson

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Corporate Tax System Complexity and Investment

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Effective tax rates of MNEs: New evidence on global low-taxed profit

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Corporate Tax Statistics 2023

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International Tax Policy's Harm to Manufacturing and National Interests

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Country-by-Country Disclosures and Firms' Internal Information Environment

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Pillar 2: QDMTT or Safe Harbour Domestic Minimum Top-Up Tax (SHDMTT)?

31 Oct 2023

‘Just BEAT It’ Do Firms Reclassify Costs to Avoid the Base Erosion and Anti-abuse Tax (BEAT) of the TCJA?

31 Oct 2023

Global Tax Evasion Report 2024

23 Oct 2023

Profit Shifting Under the Arm’s Length Principle

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The Historical Origins and Current Prospects of the Multilateral Tax Convention

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A New Scenario in International Tax Law: Two Proposals to Rethink the OECD Model in Response to the Generalization of Distance Work by Employees

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Minimum Tax Implementation Handbook (Pillar Two)

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The Multilateral Convention to Implement Amount A of Pillar One

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Explanatory Statement to the Multilateral Convention to Implement Amount A of Pillar One

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Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule

03 Oct 2023

Simplified Application of the Arm’s Length Principle for Baseline Distribution Functions offers win/win for MNEs and Tax Authorities - A Risk Management Perspective on the OECD Amount B Proposal

02 Oct 2023

Government Reputation, FDI, and Profit-shifting

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Mutual Agreement Procedure and Foreign Direct Investments: Evidence from Firm-level Data

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Tax Arbitration and Foreign Direct Investments: A comparison between developed and developing countries

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The Effect of U.S. Tax Reform on U.S. R&D-Intensive Multinational Companies

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Enigma of the United States, Base Erosion, and the Global Minimum Tax

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Globe: The Potential Costs Of Cooperation

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Targeted Measures Against Intra-Group Debt Financing: What Needs and Design Options in Light of the ATAD, Transfer Pricing Rules, and Pillar 2?

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UN MTC Article 14: The Mistaken Retention

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Global Tax Hubs

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Strategic Narratives in International Tax Policy Making: Beps Action 1 and the Stability Argument

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Can the OECD Author an Equitable International Tax Architecture?

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Transfer Price Documentation Rules and Multinational Firm Behavior - Evidence from France

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A Macroeconomic Perspective on Taxing Multinational Enterprises

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The Fundamentals of Tax Incentives

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Promotion of inclusive and effective international tax cooperation at the United Nations

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The Use and Abuse of Location-Specific Rent

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Progressive Formulary Apportionment: The Case for 'Amount D'

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Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two)

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The Influence of Macroeconomic Growth Opportunities on U.S. Effective Tax Rates on Foreign Earnings

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Pillar 2 and the Credits

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The Legitimacy Of The OECD’s Work On Pillar Two: An Analysis Of The Overconfidence In A ‘Devilish Logic’

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Tax Strategy Disclosure: A Greenwashing Mandate?

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The Effect of the Closure of the Double Irish Arrangement on the Location of U.S. Multinational Companies’ Profits

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Response to the UN Resolution A/RES/77/244 on Promotion of Inclusive and Effective Tax Cooperation at the United Nations

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Pillar I: The Marketing and Distribution Safe Harbour (MDSH) as Applicable to Licensed Manufacturers and Centralized Business Models: Does It Fulfill Its Policy Objective?

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Pillar 2 and the Bits

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Nothing New Under the Sun? The Historical Origins of the Benefits Principle

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Unitary Taxation After Pillar One

25 May 2023

Tax Implications of Contributing Appreciated Property Overseas

22 May 2023

Mandatory Binding Dispute Resolution in the Base Erosion and Profit Shifting (BEPS) Two Pillar Solution

22 May 2023

Implementing Pillar Two: Potential Conflicts with Investment Treaties

22 May 2023

Challenges at the intersection between investment provisions in regional trade agreements and implementation of the GloBE Rules under Pillar Two

20 May 2023

Intellectual Property and Tax Incentives: a Comparative Analysis of the EU and the US Legal Frameworks

20 May 2023

The Mirage of Mobile Capital

19 May 2023

Differing Abuse Concepts in Double Tax Conventions: At What Level and to What Extent Can Equality Be Realized?

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Who Really Matters in Corporate Tax?

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The Irish Apple Tax Disaster

19 Apr 2023

A Global Climate Wealth Tax to Fund a Worldwide, Just Transition

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The Global Corporate Minimum Tax: A Cure or Not?

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Public Finance in the Real World: Through the Lens (Down the Rabbit Hole?) of Transfer Pricing

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U.S. International Tax Policy and Corporate America

27 Mar 2023

Limits to Competition: Strategies for Promoting Jurisdictional Cooperation

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Global Profit Shifting of Multinational Companies: Evidence from CbCR Micro Data

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Tax Policy, Investment and Profit-Shifting

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Taxing Intellectual Property Assets on a Cross-Border Transaction: Application of Mobilia Sequuntur Personam and the Case of the India–Mauritius Tax Treaty

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Taxation of Information and the Data Revolution

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Taxing Multinationals: Three Lenses on International Tax Cooperation (Comments on UN Resolution 77/244, Promotion of Inclusive and Effective International Tax Governance at the United Nations)

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Testimony for the Hearing “Cross-border Rx: Pharmaceutical Manufacturers and U.S. International Tax Policy”

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Optimal Taxation of Multinational Enterprises: A Ramsey Approach

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Crossing the Atlantic: The role of U.S. executives in tax planning of foreign subsidiaries

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Never-Ending Battle Between Privacy and Transparency: The Case of Registers of Beneficial Ownership Before the CJEU

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Why 15%? Justifying the Global Corporate Minimum Tax

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The Canadian Digital Services Tax

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The Physical, Human Driven Digital Economy: The Overvaluation of Intangibles and its Effects on Tax and Society

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The Effects of the Tax Cuts and Jobs Act on the Tax-Competitiveness of Multinational Corporations

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Designing Domestic Minimum Taxes in Response to the Global Minimum Tax

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General Explanations of the Administration's Fiscal Year 2024 Revenue Proposals

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Trade Enforcement Tools and International Taxation: A Digital Services Tax Case Study

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Foreign Holding Companies and the US Taxation of Foreign Earnings: Evidence from TIPRA 2005

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The effect of US tax reform on the taxation of US firms’ domestic and foreign earnings

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An Indonesian Perspective on Global Tax Reform and Pillar 2

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Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two)

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Impact of Tax on Foreign Direct Investment

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Coordination of Transfer Prices on Intra-Firm Trade

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The Effect of IP Box Regimes on International IP Payments and Foreign Research and Development

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Cross-Country Evidence on the Preliminary Effects of Patent Box Regimes on Patent Activity and Ownership

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Corporate Inversions and Economic Performance

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A Comparison of the Tax-motivated Income Shifting of Multinationals in Territorial and Worldwide Countries

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Cross-Country Comparisons of Corporate Tax Systems

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The Consequences of Territorial and Worldwide Systems of International Taxation

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Investor Taxation in Open Economics

01 Aug 2009

Book-Tax Conformity: Implications for Multinational Firms

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Corporate Income Tax Burdens at Home and Abroad

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Closer Economic Integration and Corporate Tax Systems

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Expansion Abroad and the Domestic Operations of U.S. Multinational Firms

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"Taxing Multinationals," International Tax and Public Finance

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Does Acquisition by Non-U.S. Shareholders Cause U.S. Firms to Pay Less Tax

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The Effect of the Tax Reform Act of 1986 on the Location of Assets in Financial Services Firms

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Structural Estimates of Factor Substituition from Firm-Level Panel Data on Multinational Corporations

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Taxes and Cross-Border Investments: The Empirical Evidence

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What Do We Know About The Impact of Offshore Investment On The U.S. Economy

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The Compliance Cost of Taxing Foreign-Source Income: Its Magnitude, Determinants, and Policy Implications

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U.S. Interest-Allocation Rules: Effects and Policy

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Corporate Domicile and Average Effective Tax Rates: The Cases of Canada, Japan, the United Kingdom, and the United States

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Free Trade Taxation And Protectionist Taxation

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