Fresh Ideas Emerge for New EU Budget Levies

The European Parliament is considering new EU own resources that would tax online gambling, speculative real estate investment, and large companies through a turnover-based CORE contribution. The proposals expose significant legal and institutional constraints, including unanimity requirements, subsidiarity limits, especially for gambling, and unresolved questions about where digitally delivered activity should be taxed. Academic analysis warned that CORE could lead to multiple counting within corporate groups and impose tax liabilities that are disconnected from profitability, raising concerns about neutrality, legal characterization, and enforceability.  

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OECD Pillar Two and U.S. GILTI: Comparative Analysis and Policy Implications for Multinational Tax Compliance

  • By Sourav Kumar Gupta
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This paper analyzes the interaction between OECD Pillar Two and the U.S. GILTI regime, evaluating their combined impact on multinational tax compliance and global minimum tax policy.

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The Sovereignty Paradox: Digital Services Taxes, Political Jurisprudence and the Limits of State Power in the Digital Economy

  • By Arif Ansari
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This paper explores the tension between national tax sovereignty and global digital markets, analyzing how digital services taxes challenge traditional limits on state power.

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How the U.S. Constitution Shapes International Tax Law: Instrument Choice in Tax Agreements

  • By Noam Noked, Young Ran (Christine) Kim, and Reuven S. Avi-Yonah
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The authors explore how constitutional constraints influence the United States’ approach to international tax agreements, particularly the choice between treaties and executive agreements.

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Digital Services Taxes and the WTO

  • By Reuven S. Avi-Yonah
  • By Doron Narotzki
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This paper examines whether digital services taxes comply with WTO obligations and analyzes their role in the broader landscape of international tax coordination. 

Citation: Avi-Yonah, Reuven S. and Narotzki, Doron, Digital Services Taxes and the WTO (March 14, 2026). U of Michigan Law & Econ Research Paper Forthcoming, 121 Tax Notes Int’l 1223 (2026)

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International Tax Reform and Multinational Corporate Behavior: Conceptual Insights from the One Big Beautiful Bill Act

  • By Sourav Kumar Gupta
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The paper explores how recent international tax reforms could influence the behavior of multinational corporations, focusing on incentives related to profit shifting, investment location, and tax competition.

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Fiscal Limits to Protectionism: The 2025 U.S. Tariff Laffer Curve

  • By Pau Pujolas
  • By Jack Rossbach
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This paper examines whether increasing tariffs can eventually reduce government revenue by shrinking trade flows, applying the concept of a Laffer Curve to recent U.S. tariff policy and global trade dynamics.

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Hidden Profits, Lost Jobs? Tax Havens and Employment Decisions

  • By Ronald B. Davies, Margarita Lopez-Forero, Benjamin Michallet, and Johannes Scheuerer
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The study examines how multinational firms’ use of tax havens affects employment decisions, exploring whether profit shifting alters job creation and investment patterns across countries.

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What is the Share of U.S. Tariffs Paid by Exporters?

  • By Marco Fugazza
  • By Marcelo Olarreaga
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This paper investigates how the burden of U.S. tariffs is distributed between foreign exporters and domestic consumers, providing new evidence on tariff incidence in global trade.

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The “Hidden Sides” of the Taxation of Dividends and Interest for Corporate America versus Corporate Europe

  • By Domenico Imparato
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This paper compares how dividend and interest taxation differs between the United States and Europe, highlighting structural differences in corporate tax systems and their implications for multinational firms.

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Tariffs and Firm Expectations

  • By Klaus Abberger, Arbërim Bibaj, Hans Gersbach, Alexis Perakis, Alexander Rathke, Samad Sarferaz, and Kieran James Walsh
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This paper examines how tariff policies influence firms’ expectations about investment, production, and economic conditions, highlighting how trade policy uncertainty affects corporate decision-making.

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