Papers & Reports

This article analyzes how di¤erences in production technology, nancial frictions, time discount rates, and tax policies collectively determine the long-run asset positions and wealth distribution between countries. It contributes to understanding how national policies and economic factors shape global wealth patterns over time.

In this update, the authors analyze new data from the US Treasury to examine historical revenue effects of TCJA’s international corporate tax provisions. They also provide updated conventional estimates to assess the revenue impact of scheduled 2026 rate increases on foreign income of US corporations and assess several proposals that aim to further increase tax revenue.

Taxation of cross-border services has been identified as a high priority issue in the UN negotiations to establish a new global framework for tax. This paper analyses the defects of international tax rules as applied to services, and their exploitation by multinational enterprises, focusing on the impact on developing countries. It analyses the restrictions on source taxation of services in tax treaties, particularly those based on the model of the OECD, and shows that their spread has been accompanied by a widening deficit in services trade of developing countries, while the weakening of their attempts to protect their tax base through withholding taxes has resulted in increasing losses of tax revenue. The analysis suggests that a new approach is needed for taxation of services, breaking with the residence-source dichotomy, and adopting formulary apportionment. This could be based on the standards agreed in the Two Pillar Solution of the OECD/G20 project on base erosion and profit shifting and developed now through the UN.

This study contends that case law involving the EU banking union indicates that the EU has legal grounds to levy a contribution on companies in exchange for services.

This is the ninth edition of Tax Policy Reforms: OECD and Selected Partner Economies, an annual publication that provides comparative information on tax reforms across countries and tracks tax policy developments over time. The report covers the tax policy reforms introduced or announced in 2023 in 90 member jurisdictions of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting, including all OECD countries. The publication provides an overview of the macroeconomic environment and tax revenue context in which these tax reforms were made, highlighting how governments used tax policy to respond to elevated inflation levels, as well as to address long-run structural challenges.

This article highlights Nigeria's potential to diversify its economy and drive innovation through its expanding youth population and digital ecosystem. To capitalize on these opportunities, the country needs to implement a swift and adaptive taxation strategy. Addressing the challenges of taxing the digital economy, Nigeria is exploring innovative solutions, including revising international tax rules and adopting digital-first policies. This proactive approach positions the nation to shape its economic future in the digital era.

This letter provides comments on the Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global AntiBase Erosion Model Rules (Pillar Two), published on 17 June 2024 and the additional interpretative CbCR guidance released on 27 May 2024. The NFTC requests that the OECD solidify safe harbors, ensure consistent application of the rules, clarify the implementing mechanism, and develop a dispute resolution mechanism.

This study examines corporate inversions, where multinational enterprises relocate their global ultimate owner (GUO) to another jurisdiction, complicating the identification of MNEs' country of origin and foreign subsidiaries. Using data from over 52,000 MNEs across 30 nations, the study hypothesizes that emerging market MNEs (EMNEs) and larger MNEs with extensive foreign networks are more likely to invert. The findings confirm this, highlighting differences between inverted and non-inverted MNEs, which can lead to sampling biases in research. The study suggests methodological adjustments to improve the accuracy of cross-country MNE analyses.

This article analyzes the potential negative effects of raising corporate tax rates, focusing on Kamala Harris's proposal to increase the U.S. corporate tax rate from 21% to 28%. It draws on examples from the Trump administration's tax cuts and international case studies from Ireland, Germany, and the UK. The article highlights the risks to business investment, job creation, and economic growth, noting that while higher taxes can increase public revenue, they may also discourage investment, reduce competitiveness, and hinder long-term growth. The analysis underscores the need for policymakers to balance revenue generation with maintaining a healthy business environment.

The peer review of the Action 13 Minimum Standard covers the three key areas under review: the domestic legal and administrative framework, the exchange of information framework, and the confidentiality and appropriate use of Country-by-Country (CbC) reports. This seventh annual peer review report reflects the outcome of the seventh review which considered all aspects of implementation. It contains the review of 138 jurisdictions which provided legislation or information pertaining to the implementation of CbC Reporting.