2026
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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The Paradox of Reporting Without Visibility: How DAC8 And CARF Expose the Limits of Transparency-Based Taxation in Crypto-Assets
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U.S. Tax Reform and International Trade
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Tax Inspectors Without Borders Annual Report 2026
This report reviews the work of the Tax Inspectors Without Borders initiative, a joint OECD/UNDP program supporting developing jurisdictions in tax audits, enforcement, and international tax administration. It highlights how capacity-building programs are being used to strengthen audit outcomes, address cross-border tax issues, and combat illicit financial flows through practical assistance to tax authorities.
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30 Years of Research on Income Shifting—Review and Looking Ahead
This paper provides a structured survey of three decades of empirical research on tax-motivated income shifting by multinational corporations. It organizes the literature around the mechanisms, determinants, consequences, and estimated magnitudes of income shifting, and identifies areas where future research could improve measurement methods and expand analysis of multinational tax planning behavior.
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Statutory Measures Adopted by Pakistan to Tax Cross-Border Digital Transactions: Inconsistencies and Inadequacies?
This article examines Pakistan’s statutory regime for taxing cross-border digital transactions and its interaction with international tax rules. It focuses on the coexistence of Pakistan’s digital tax measures with its double tax agreements, including questions involving permanent establishment, business nexus, duplication across multiple legislative instruments, and enforcement by domestic tax authorities.
Citation: Khan Niazi, Shafi Ullah, Statutory Measures Adopted by Pakistan to Tax Cross-Border Digital Transactions: Inconsistencies and Inadequacies? (March 31, 2026). Statute Law Review, Volume 47, No. 2. pp. 1-19.
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Crypto Taxation: Challenges in Defining and Regulating Digital Assets in the EU and Beyond
This paper examines the tax treatment of crypto-assets in the European Union and compares the EU approach with developments in the United Kingdom, United States, Singapore, and the UAE. It focuses on the gap between harmonised financial regulation under MiCA and fragmented tax rules across jurisdictions, with particular attention to DAC8, the OECD Crypto-Asset Reporting Framework, classification problems, enforcement gaps intensified by anonymity and decentralised finance, and divergent implementation rules.
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Who Taxes Your Salary When You Work From Home? International Tax Treaties and Cross-Border Telework
This article examines how international tax treaties allocate taxing rights over dependent employment income in an era of remote work, frontier work, and digital mobility. Focusing on Article 15 of the OECD Model Tax Convention, the author argues that existing rules are no longer adequate for cross-border telework and proposes a reform based on the Ottawa Taxation Framework and labor neutrality principles.
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Who Bears the Burden of Digital Services Taxes?
This paper examines the incidence of digital services taxes imposed on large digital platforms, focusing on whether the burden is borne by platforms or passed on to advertisers through higher advertising prices. Using Google Ads data across 29 European countries, the authors find that advertisers bear a substantial share of the tax burden, with evidence of near-complete pass-through through higher effective costs per click.
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Fundamentals of Indirect Taxation
This volume provides a comparative overview of major transaction-based taxes, including VAT/GST, customs duties, tariffs, excise duties, environmental taxes, digital services taxes, and taxes on capital transfers. It situates indirect taxation in a global context by drawing on examples from multiple jurisdictions and referencing OECD, IMF, UN, and EU standards, with attention to the challenges posed by digitalization, globalization, and environmental policy.
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Navigating the Amazon: The Incidence of Digital Service Taxes
This paper examines the incidence of digital service taxes, focusing on how such taxes affect prices and tax burdens in platform markets such as Amazon. By studying who ultimately bears the cost of taxes imposed on large digital platforms, the paper contributes to debates over the economic effects of unilateral digital tax measures.
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Shrinking Tax Sovereignty In Canada? Evidence from the Income Tax Act
This paper examines whether Canada’s tax sovereignty has narrowed as domestic legislation increasingly responds to international tax coordination and cross-border tax challenges. It uses changes to the Income Tax Act to consider how far national tax autonomy may be constrained by external pressures, coordinated standards, and the need to respond to international tax planning.
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Retaliatory Taxation and the Birth of America's First Tax Treaty
This article examines the historical origins of retaliatory taxation in the United States and its relationship to the development of America’s first tax treaty. Cui uses newly examined historical materials to show how retaliatory tax measures and treaty-based cooperation emerged as competing approaches to international tax conflict.
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Trade Agreements and Domestic Policy under Variable Markups
This article looks at how trade agreements affect domestic policy when firms set prices with variable markups. It walks through how those international rules can end up shaping tax and regulatory decisions at the national level, especially when governments are trying to balance trade commitments with their own fiscal priorities. It also touches on what that means for competitiveness across borders and the practical difficulty of lining up international obligations with domestic policy goals.
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References to Dynamic International Standards and the Tax Legality Principle
This article looks at the gap between evolving international tax standards, like OECD guidance, and the legality principle in domestic tax law. It raises concerns about whether relying on constantly changing international rules actually meets requirements of legal certainty and democratic accountability. The discussion ties this tension to BEPS-related reforms and the growing use of administrative guidance.
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MNE Roadkill? Why Pillar 2 Survives With or Without the U.S.
This paper evaluates the durability of the OECD’s Pillar Two global minimum tax regime in the absence of U.S. participation. It argues that structural incentives and coordinated implementation by other jurisdictions may sustain the regime regardless of U.S. policy choices.
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The Role of Residence-Based Taxation in Business Income Taxation
This paper revisits the role of residence-based taxation in allocating taxing rights over business income in a globalized economy. It evaluates how residence principles interact with source-based rules and modern challenges such as digitalization.
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Citation: Bulletin for International Taxation 2026 (Volume 80), No. 4/5.
US-China Cooperative Interdependence: Opportunities and Obstacles
This paper looks at the economic relationship between the United States and China, focusing on how closely the two systems are tied together and how that shapes trade and tax decisions. It considers both the potential for cooperation and the growing risk of economic fragmentation, along with the effects on global tax coordination and multinational investment. It also discusses how rising geopolitical tensions are influencing international tax policy and cross-border economic strategy.
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Citation: Peterson Institute for International Economics Briefing 26-2
Arthur Cockfield's Digital Economy: A Retrospective Analysis
This paper evaluates the evolution of digital economy taxation through the lens of Arthur Cockfield’s scholarship. It examines how early conceptual frameworks anticipated current challenges in taxing digital business models. The analysis is particularly relevant to ongoing OECD reforms and debates over digital services taxation.
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Citation: Forthcoming, Canadian Tax Journal (Special Issue: Tax Sovereignty in a Digital and Divided World: A Tribute to Arthur Cockfield)
Taxing Data as the New Oil
This article explores the conceptual and practical challenges of taxing data as an economic asset within the international tax framework. It considers whether existing rules can capture value generated through data-driven business models and proposes potential reforms.
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Can Sales Destinations Reclaim Taxing Rights on Profits from Cross-Border Sales of Goods on Digital Platforms?
This article examines whether destination countries can assert taxing rights over profits generated through digital platform-based cross-border sales. It analyzes evolving international tax principles, including destination-based taxation and the shift away from traditional source rules. The paper is particularly relevant to ongoing reforms addressing digital economy taxation and allocation of taxing rights.
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Citation: Fei Gao and Richard Krever, ‘Can sales destinations reclaim taxing rights on profits from cross-border sales of goods on digital platforms?’ [2025](3) British Tax Review 363-385.
The Largest Tax Fraud?
This paper evaluates large-scale international tax avoidance structures and questions whether certain widely used arrangements effectively amount to systemic tax fraud. It focuses on enforcement gaps in cross-border taxation and the role of governments in enabling or constraining aggressive tax planning. The analysis contributes to ongoing debates over transparency, compliance, and the limits of current international tax enforcement frameworks.
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International Taxation and the Frustrations of Formulary Apportionment Estimation
This article evaluates the practical and theoretical difficulties of implementing formulary apportionment in international taxation, particularly the challenges of estimating appropriate allocation factors across jurisdictions. It contributes to ongoing debates about alternatives to arm’s length pricing in a BEPS-influenced environment.
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The Awkward Implications of an Undertaxed Profits Rule
This paper analyzes the unintended consequences of the Undertaxed Profits Rule under Pillar Two, including compliance burdens, allocation distortions, and enforcement complexity. It raises concerns about how the rule operates in practice across jurisdictions with differing tax regimes.
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Should I Stay or Should I Go? The Impact of Taxation on Canadian Inter-Provincial Migration
This study examines how differences in regional tax policies influence migration decisions within Canada, highlighting behavioral responses to subnational tax variation. The findings have broader implications for tax competition and mobility in multi-jurisdictional systems.
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Quantifying Climate Damages When Regions Trade: A Structural Gravity Approach
This paper evaluates how international trade transmits climate-related economic damages across regions, using a structural gravity framework. It provides insight into cross-border externalities and raises important considerations for tax and policy instruments addressing climate change.
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Corporate Taxation And Data Centers
This paper examines how corporate tax systems interact with the growing importance of data centers, focusing on jurisdictional allocation of profits and the challenges digital infrastructure poses for traditional nexus and sourcing rules. It highlights broader implications for international tax policy as economies become increasingly data-driven.
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Citation: Avi-Yonah, Reuven S., Corporate Taxation And Data Centers (April 04, 2026). U of Michigan Law & Econ Research Paper Forthcoming
Impact of Environmental Measures on International Trade (with focus on EU CBAM & WTO law)
This paper examines the interaction between environmental policy and international trade law, focusing on the EU’s Carbon Border Adjustment Mechanism (CBAM). It analyzes how CBAM may function as a de facto tax on imports and evaluates its compatibility with WTO non-discrimination principles. The piece highlights tensions between climate policy and global trade obligations, raising implications for cross-border tax policy and enforcement. It is particularly relevant for understanding how environmental measures can reshape international tax and trade frameworks.
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Carbon Taxes and ESG Compensation
This paper examines how carbon taxation interacts with executive compensation structures tied to ESG performance metrics. It highlights how environmental tax policies influence firm-level incentives and cross-border corporate behavior. The analysis is relevant to international tax discussions as carbon taxes increasingly function as quasi-border adjustments and interact with global tax coordination efforts. It contributes to broader debates on how tax systems incorporate sustainability objectives and affect multinational decision-making.
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Dynamic Adjustment to Trade Shocks
This study examines how firms and economies adjust over time to trade shocks, including tariffs and global supply disruptions. It provides empirical evidence on how trade policy changes influence production, investment, and cross-border economic activity. The findings are relevant to international tax policy because trade shocks often trigger changes in profit allocation, transfer pricing strategies, and jurisdictional tax bases. The paper helps contextualize how tax systems respond to shifting global trade dynamics.
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Tax Compliance Costs of Pillar Two – A Qualitative Study
This paper evaluates the administrative and compliance burdens associated with the OECD’s Pillar Two global minimum tax regime. Through qualitative analysis, it highlights the complexity multinational enterprises face in implementing new reporting and calculation requirements. The study raises concerns about disproportionate compliance costs relative to expected revenue gains. It contributes to ongoing discussions about the practicality and efficiency of global minimum tax rules in international tax policy.
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Tax Compliance Costs of Pillar Two - A Qualitative Study
This study explores the administrative and compliance costs associated with implementing Pillar Two’s global minimum tax regime. It highlights the disproportionate burden on multinational enterprises and tax authorities, raising questions about efficiency and long-term enforceability.
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OECD Pillar Two and U.S. GILTI: Comparative Analysis and Policy Implications for Multinational Tax Compliance
This paper analyzes the interaction between OECD Pillar Two and the U.S. GILTI regime, evaluating their combined impact on multinational tax compliance and global minimum tax policy.
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The Sovereignty Paradox: Digital Services Taxes, Political Jurisprudence and the Limits of State Power in the Digital Economy
This paper explores the tension between national tax sovereignty and global digital markets, analyzing how digital services taxes challenge traditional limits on state power.
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How the U.S. Constitution Shapes International Tax Law: Instrument Choice in Tax Agreements
The authors explore how constitutional constraints influence the United States’ approach to international tax agreements, particularly the choice between treaties and executive agreements.
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Digital Services Taxes and the WTO
This paper examines whether digital services taxes comply with WTO obligations and analyzes their role in the broader landscape of international tax coordination.
Citation: Avi-Yonah, Reuven S. and Narotzki, Doron, Digital Services Taxes and the WTO (March 14, 2026). U of Michigan Law & Econ Research Paper Forthcoming, 121 Tax Notes Int’l 1223 (2026)
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International Tax Reform and Multinational Corporate Behavior: Conceptual Insights from the One Big Beautiful Bill Act
The paper explores how recent international tax reforms could influence the behavior of multinational corporations, focusing on incentives related to profit shifting, investment location, and tax competition.
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Fiscal Limits to Protectionism: The 2025 U.S. Tariff Laffer Curve
This paper examines whether increasing tariffs can eventually reduce government revenue by shrinking trade flows, applying the concept of a Laffer Curve to recent U.S. tariff policy and global trade dynamics.
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The “Hidden Sides” of the Taxation of Dividends and Interest for Corporate America versus Corporate Europe
This paper compares how dividend and interest taxation differs between the United States and Europe, highlighting structural differences in corporate tax systems and their implications for multinational firms.
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From Physical Presence to Digital Participation Toward a Participation-Based Nexus Doctrine in State Taxation
This article explores the evolution of nexus standards in U.S. state taxation from traditional physical presence to digital participation models. It analyzes how participation-based doctrines attempt to capture value creation in digital markets and considers the implications for cross-border commerce and remote sellers. The paper contributes to ongoing debates over digital nexus, economic presence standards, and the broader transformation of taxing rights in an increasingly digitalized economy.
Options for a Protocol on Services under the UN Framework Convention on International Tax Cooperation
This paper examines potential design options for a services-focused protocol under the emerging UN Framework Convention on International Tax Cooperation. It addresses core international tax challenges in services taxation, including nexus, source rules, allocation of taxing rights, and enforcement mechanisms in a digital and cross-border economy. The authors situate the proposal within the broader shift from OECD-centered rulemaking toward a more plural multilateral architecture. For international tax practice and policy, the piece is directly relevant to ongoing debates about institutional legitimacy and the reallocation of taxing rights.
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Tax Incentives for Nigerian Oil and Gas Companies under the Nigeria Tax Act
This article examines the structure and policy rationale of tax incentives applicable to Nigeria’s oil and gas sector. It evaluates how incentive design affects investment behavior, revenue stability, and effective tax rates in a capital-intensive industry with significant cross-border participation. The paper also considers how domestic incentive regimes interact with multinational structuring and treaty-based relief. For international tax analysis, it offers insight into how sector-specific incentives shape cross-border investment planning.
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