Fresh Ideas Emerge for New EU Budget Levies

This paper analyzes 6,050 disclosed royalty licensing agreements from seven jurisdictions to measure the informational value of commonly observable comparability factors in external royalty comparable searches for transfer pricing. It finds that licensor identity explains substantially more variation in royalty rates than commonly observable comparability factors, supporting greater reliance on internal comparables and suggesting that public external comparables may often be more useful for establishing arm’s-length ranges than for deriving a precise pricing benchmark.  

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This paper proposes amendments to the draft protocol on the taxation of income from cross-border services under the UN Framework Convention on International Tax Cooperation. It evaluates provisions on taxes covered, royalties, dual residence, service fees, automated digital services, physical presence, and relief from double taxation, and recommends treaty language intended to improve the protocol’s administrability, particularly for capital-importing countries.

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This paper examines why cultural and creative tax incentives that are formally available across multiple jurisdictions often remain inaccessible to cross-border operators in practice. It introduces the Structural Fiscal Access Constraints (SFAC) model to identify legal, administrative, and institutional barriers to cross-border access and proposes the Cultural-Creative Tax Incentive Model (CCTIM), a coordination framework designed to improve access without requiring tax harmonization or the transfer of national fiscal sovereignty.

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Develops the Source Sovereignty Framework (SSF), a continental proposal under which African states would coordinate as a bloc to tax cross-border income at its source through gross-basis withholding integrated into African payment systems. The paper proposes an African Union legal framework, a phased transition away from the existing bilateral treaty network, and anti-defection mechanisms, while arguing that the approach could strengthen African control over cross-border taxation and substantially increase tax revenues.

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Examines whether the OECD’s Side-by-Side Package can be reconciled with the institutional structure of Pillar Two after exempting U.S.-parented groups from the Income Inclusion Rule and Undertaxed Profits Rule despite a 14% U.S. minimum tax. The paper concludes that the accommodation is likely to be permanent, entrenching fragmentation in global minimum tax governance rather than achieving universal implementation.

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Presents empirical and survey evidence on how U.S. multinational enterprises respond to the Global Minimum Tax. Using corporate disclosures, ownership data, and a survey of U.S. tax directors, the authors find that U.S. multinationals are more likely than their European counterparts to restructure ownership chains to reduce Pillar Two exposure and that strategic organizational changes, together with policy responses by low-tax jurisdictions, substantially attenuate the intended effects of the Global Minimum Tax.

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This paper provides a technical primer on the Fifth Session zero-draft protocol on the taxation of cross-border services under the proposed UN Framework Convention on International Tax Cooperation. It explains the draft’s treaty-style structure, including provisions on the allocation of taxing rights, relief from double taxation, dispute settlement, and administrative assistance, and identifies key innovations and gaps that may be addressed during the negotiation process.

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This article examines what the authors describe as a paradox in U.S. federal tax policy: rejecting broad-based consumption taxation while relying on tariffs as a source of federal revenue. It traces the historical development of U.S. tax and tariff policy, presents empirical models of the economic consequences of this policy choice, and compares tax systems in other countries in outlining potential approaches to federal revenue reform.

Citation: 14 Tex. A&M L. Rev. __ (forthcoming 2026).

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This essay examines the legal authority of the U.S. president to impose secondary tariffs on countries that trade with targeted states, including Iran, Russia, Venezuela, and Cuba. It considers whether existing U.S. law authorizes the use of tariffs as instruments of indirect economic coercion and whether wartime circumstances affect the scope of presidential tariff authority in light of the Supreme Court’s decision in Learning Resources. The authors also consider whether Congress should delegate such tariff powers to the executive and, if so, under what constraints.

Citation: 120 Am. J. Int’l L. _ (2026).

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This paper examines the continuing relevance of the place of effective management (POEM) test for corporate tax residence under India’s Income Tax Act following the OECD’s BEPS 2.0 reforms. It argues that the Pillar Two Global Anti-Base Erosion (GloBE) rules reduce POEM’s traditional anti-avoidance role for large multinational enterprises by emphasizing effective tax rates rather than jurisdictional residence, while concluding that POEM remains relevant for entities outside the scope of Pillar Two, treaty residence determinations, and governance-based tax planning. The paper also examines the interaction between POEM and Pillar Two, highlighting areas of regulatory overlap, conceptual divergence, and increased compliance costs.

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