The Determinants of the EU Tax Haven List
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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Hong Kong's Strategic Tax Policies for Innovation and R&D: Navigating Regional Competition and Global Minimum Tax Compliance
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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Balancing Acts: Tariffs, Proportionality, and the EAC Common Market
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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Reimagining Fiscal Sovereignty: Digitalization And the Emerging Legal Frontiers of Tax Administration in Nigeria
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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Taxation and Deglobalization
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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Challenges of Taxing Business Profits Arising from Digital Transactions in Rwandan Law: A Critical Analysis of the Legal Framework and the Way Forward
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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MNE Responses to the Global Minimum Tax
This OECD Taxation Working Paper provides an early empirical, ex post assessment of how multinational enterprises responded to the introduction of the Global Minimum Tax. Using the EUR 750 million revenue threshold and firm-level data, it examines the reform’s effects on effective tax rates, investment, and employment, as well as whether MNEs adjusted their behavior in anticipation of implementation. The paper also uses its estimated effects on effective tax rates to assess the potential revenue raised by the Global Minimum Tax in its first year.
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Measuring Location-Specific Rents
This article examines location-specific rents as a basis for allocating taxing rights among sovereign states and addresses the practical challenge of measuring such rents. It argues that tax competition can help quantify the income international firms derive specifically from operating in a particular jurisdiction. The analysis has implications for inter-nation equity and the allocation of source-country taxing rights in international taxation.
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From "Reporting" to "Rule-of-Law": Digital Governance as a Defensive Shield Against Administrative Discretion in Emerging Markets
This paper examines tax compliance challenges faced by multinational enterprises operating in emerging markets, focusing on administrative discretion, regulatory ambiguity, and aggressive tax audits. Using a mining project in Sierra Leone as a case study, it analyzes how a multinational enterprise responded to a contested tax assessment and argues for digital compliance systems as a means of institutionalizing tax controls and reducing exposure to discretionary enforcement. The paper highlights the role of internal tax governance and digitalization in managing tax risk in weak institutional environments.
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Jane Street Capital's Indian Tax Battle Begins
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