Fresh Ideas Emerge for New EU Budget Levies

This article examines the evolution of international tax treaty anti-abuse mechanisms addressing treaty shopping and tax avoidance, using Aiken Industries as a starting point to analyze the balance between legal certainty and interpretive flexibility. It considers mechanisms including beneficial ownership, the Principal Purpose Test, and Limitation on Benefits rules, and explores how artificial intelligence could assist in interpreting and applying such measures. The article also addresses risks associated with the use of AI in tax administration, including transparency, explainability, and regulatory compliance.

Citation: International Tax Studies, volume 9, issue 4, 2026[10.59403/2fvstnv], Available at SSRN: https://ssrn.com/abstract=7071158

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This dissertation examines the arm’s length standard from the perspective of developing and dependent economies, assessing both empirical and theoretical critiques of its application in international transfer pricing. It considers the OECD’s current treatment of the standard, including the two-pillar framework, and analyzes alternative practices such as Brazil’s fixed margins and China’s Location Specific Advantages. The author ultimately proposes an experimentalist governance model that would allow developing countries to adopt and peer-review similar approaches, particularly where limited fiscal capacity makes enforcement of the traditional arm’s length standard difficult.

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The OECD reports the latest peer review results for preferential tax regimes under the BEPS Action 5 minimum standard, using the revised peer review methodology for the first time. The Forum on Harmful Tax Practices reached conclusions on 13 regimes: seven were found “not harmful,” while six in Azerbaijan, Malaysia, Peru, and Serbia remain “under review.” Since the BEPS Project began, the Forum has reviewed 347 regimes, more than 40 percent of which have been or are being abolished.

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Using data covering 223 tax systems, this paper examines how jurisdictions have responded to the OECD Pillar Two framework and finds substantial differences in its implementation. It finds that the long-term decline in statutory corporate income tax rates appears to have slowed since the 2021 agreement, while low-tax jurisdictions continue to compete through substance-based tax incentives and preferential regimes designed to interact favorably with Pillar Two rules.

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This paper examines the factors determining inclusion on the EU list of non-cooperative tax jurisdictions. It finds that countries with greater financial secrecy and less economic bargaining power with the EU are more likely to be listed, while some excluded EU tax havens share characteristics with listed non-EU jurisdictions.

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This article examines Hong Kong’s patent box regime in light of regional tax competition and the OECD global minimum tax. It proposes refundable tax credits, increased government grants and subsidies, and additional individual income tax incentives to make Hong Kong’s innovation policies more compatible with the GloBE rules.

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This article examines how courts in the East African Community assess national tax and tariff measures that may conflict with common-market commitments. It argues for an explicit proportionality framework to balance states’ fiscal autonomy with the free movement of goods and the integrity of the EAC Common Market.

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This paper examines Nigeria’s shift toward digital tax administration and the resulting issues involving data protection, cybersecurity, taxpayer rights, and regulatory fragmentation. It also addresses the taxation of cross-border digital activities and considers OECD initiatives in the context of Nigeria’s evolving digital tax framework.

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This article examines how the shift away from globalization may reshape taxation and tax policy. It analyzes the relationship among globalization, tax competition, capital mobility, and the financing of social safety nets, arguing that deglobalization may give governments greater room to raise revenue without the same degree of tax-base erosion associated with international tax competition. The article also considers the potential revenue implications of higher tariffs and reduced tax evasion.

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This paper examines the structural challenges facing Rwanda in taxing business profits arising from digital transactions. It analyzes gaps in the country’s digital tax framework, including limitations in permanent establishment and digital nexus rules, as well as jurisdictional and enforcement challenges. The paper also considers international responses to digitalization, including the OECD/G20 Pillar One and Pillar Two framework, and recommends reforms addressing digital presence, bilateral tax treaties, and regional coordination within the East African Community.

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