Papers & Reports

This paper is part of a series of papers by the UF Tax Incubator presented in connection with a symposium hosted by the American Enterprise Institute June 17-18, titled “Complexities, Discontinuities, and Unintended Consequences of U.S. International Tax Rules: Options for Change.”

The UF Tax Incubator working group unravels the intricacies of the United States’ source of income rules, examining some of the pitfalls and difficulties associated with the rules and suggesting potential reforms and alternatives that could simplify and update the system.

The global minimum tax should prompt countries to analyze the potential impact on tax incentives and options for reform, including incentives in special economic zones (SEZs) This policy brief aims to contribute to building the understanding of SEZ authorities and investment and tax policy-makers on the growing need for reform of tax incentives and the impact this will have on the typical benefits they offer to investors. It emphasizes the need for countries to critically assess whether tax incentives remain a priority for investment promotion; whether they have been a help or hindrance to zones; and how new international tax standards impact their design and use, as well as opportunities for reform.

This article explores whether international tax law is part of public international law. While international lawyers typically view international tax law as a subset of international law, international tax lawyers often see themselves primarily as tax specialists rather than international law experts. This distinction arises because international tax law focuses on concepts like residence and source jurisdiction, rather than nationality and territoriality, indicating substantive differences. 

This paper questions the effectiveness of bilateral investment treaties (BITs) in protecting investors from the qualified domestic minimum top-up tax (QDMTT) under Pillar 2.

This is the sixth edition of Corporate Tax Statistics, an annual publication that brings together information on corporate taxation and base erosion and profit shifting (BEPS) practices that previously were unavailable to tax policy researchers and policymakers. This includes data on corporate tax rates, revenues, effective tax rates (ETR), tax incentives for research and development (R&D) and innovation, and withholding taxes amongst other data series. Corporate Tax Statistics also includes anonymised and aggregated Country-by-Country Reporting (CbCR) data providing an overview on the global tax and economic activities of thousands of large multinational enterprise groups perating worldwide.

This article argues that market jurisdictions' taxing rights under Pillar One are justified by widely accepted principles in international taxation. These principles—such as ability to pay, the benefits principle, and economic allegiance—provide a normative basis for tax jurisdiction and are essential for the legitimacy and equity of the international tax regime. Despite criticisms of their vagueness and overlaps, the benefits principle and economic allegiance play a crucial role in designating countries with a legitimate claim to tax international income. The article contends that a principled allocation of taxing rights is not only desirable but a moral necessity for international coordination.

To read more go here

In this symposium paper, the UF Tax Incubator working group examines some of the problems with the U.S. transfer pricing rules and suggests incremental legislative changes to improve the functioning of those rules.

This document provides guidance clarifying and simplifying the application of the global minimum tax and an overview of the streamlined process for recognising qualified status for the legislation of jurisdictions implementing the Global Anti-Base Erosion (GloBE) Rules.

This document sets out the fourth set of Administrative Guidance released by the Inclusive Framework. It includes guidance on application of the recapture rule applicable to deferred tax liabilities (DTL), including how to aggregate DTL categories and methodologies for determining whether a DTL reversed within five years. This guidance also clarifies how to determine deferred tax assets and liabilities for GloBE purposes when the rules result in divergences between GloBE and accounting carrying value of assets and liabilities. It also includes further guidance on cross-border allocation of current and deferred taxes, allocation of profits and taxes in certain structures involving Flow-through Entities, and the treatment of securitisation vehicles.