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Can Investment Treaties Defeat Pillar 2?

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Papers & Reports
Can Investment Treaties Defeat Pillar 2

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Whither The Un Framework Convention?

11 Nov 2024

On Pillar Two controversy and trust

07 Nov 2024

The OECD's Work on Profit Allocation and Nexus Rules for a Digitalized Economy: A Potential Improvement of the International Taxation Framework?

04 Nov 2024

Cloud Computing: Difficulties in Applying Current and Proposed Nexus and Profit Allocation Rules in a Cross-Border Scenario

04 Nov 2024

Value Creation: A Guiding Light for the Interpretation of Tax Treaties?

04 Nov 2024

Remarks on the Future Prospects of the OECD/G20 Programme of Work: Profit Allocation (Pillar One) and Minimum Taxation (Pillar Two)

04 Nov 2024

A Multilateral Interpretation of the Multilateral Instrument (and Covered Tax Agreements)?

04 Nov 2024

A New Pillar to Address Tax Challenges Arising from Digitalization of the Economy: Consensus-Based Digital Services Taxes?

04 Nov 2024

Taxation of Income from Cross-Border Services: A Global Normative and Enforcement Approach to Legal Issues and Policy Options

31 Oct 2024

The True Nature of Tax Treaties

29 Oct 2024

International Tax Implications for Private Equity Investments

29 Oct 2024

Measuring Tax Burden Efficiency in OECD Countries: An International Comparison

28 Oct 2024

Reimagining Global Tax Governance: A Two-sided Platform Perspective

28 Oct 2024

Proposal for a Council Directive Amending Directive 2011/16/EU on Administrative Cooperation in the Field of Taxation

28 Oct 2024

OECD Secretary-General Tax Report to G20 Finance Ministers and Central Bank Governors (G20 Brazil, October 2024)

24 Oct 2024

Capital Flows and Wealth Distribution in a Global Economy with Asymmetric Countries

23 Oct 2024

Update on the Revenue Effects of GILTI and FDII, 2026 Rate Changes, and Proposed Policy Reforms

15 Oct 2024

The Implications of Treaty Restrictions of Taxing Rights on Services, Especially for Developing Countries

14 Oct 2024

10 Years of Banking Union’s Case-Law: How Did European Courts Shape Supervision and Resolution Practice in the Banking Union?

03 Oct 2024

Tax Policy Reforms 2024: OECD and Selected Partner Economies

30 Sep 2024

Digital Economy & Taxation: Challenges and Opportunities In Nigeria

27 Sep 2024

Comment Letter on the June 2024 Administrative Guidance

26 Sep 2024

Corporate Inversions and the Global Ultimate Owner: Challenges in International Business Research

18 Sep 2024

How Kamala Harris's Tax Hike Could Affect Business Growth

18 Sep 2024

Country-by-Country Reporting – Compilation of 2024 Peer Review Reports

16 Sep 2024

The EU's Uncoordinated Approach to Tax Avoidance and Tax Abuse in Relation to 'Uncooperative' Tax Jurisdictions

16 Sep 2024

Reimagining Tax Treaty Dispute Resolution; beyond MAP and Arbitration

13 Sep 2024

Cross-Border Taxation in a World of Abundant Capital

12 Sep 2024

International Compliance Assurance Programme (ICAP) Outcome Letter Template

11 Sep 2024

The Future of European Competitiveness – A Competitiveness Strategy for Europe

09 Sep 2024

The Subject to Tax Rule: A Comparison of The OECD and UN Versions

03 Sep 2024

Tokenization: Unlocking Developing Countries Wealth

03 Sep 2024

FTC Proposals, Part II: TCJA White Paper

27 Aug 2024

An Investigation of the Array of Domestic and Foreign Tax Haven Location Decisions for U.S. Multinational Firms

26 Aug 2024

Why the U.N. Must Put AI and Data on the Tax Agenda

26 Aug 2024

International Tax Scholarship and International Tax Activism

22 Aug 2024

FTC Proposals, Part I: Creditable Foreign Taxes

20 Aug 2024

Climate Policies and External Adjustment

19 Aug 2024

A New Governance Framework in Cross-Border Tax Policymaking

19 Aug 2024

Chair’s Proposal for Draft Terms of Reference for a United Nations Framework Convention on International Tax Cooperation

15 Aug 2024

Taxation of the Digital Economy: An Appraisal of the Effectiveness of the OECD Tax Deal on Low-and-Middle Income Countries

14 Aug 2024

Globalization, Erosion of Tax Base, and the Revenue Potential of Developing Asia's Foreign Exchange Reserve Build-Up

13 Aug 2024

Potential Changes to Section 367 and the Associated Treasury Regulations

07 Aug 2024

A Global Perspective on the Incidence of Monopoly Distortions

05 Aug 2024

International Tax Reform and the Biden-Harris Tax Pledge

05 Aug 2024

Subpart F and GILTI Recommendations

31 Jul 2024

Taxation of Foreign-Derived Intangible Income

30 Jul 2024

Power and Expertise in Global Tax Governance

30 Jul 2024

India’s Pillar Two Pledge May Have Limited Impact, Experts Warn.

30 Jul 2024

U.S. Ownership of Foreign Stock: Dividends and Gains on Sale

24 Jul 2024

U.S. Subsidiaries of Foreign-Based MNEs — BEAT and Section 163

23 Jul 2024

Interpreting Tax Treaties: The Importance of Post-Treaty Commentary to the OECD Model Tax Convention for Achieving Uniformity and Ensuring the Success of the New International Tax Order

22 Jul 2024

Mulilateral Tax Reform

22 Jul 2024

The Taxation of Robots and Its Global Challenges

22 Jul 2024

Revised Draft Terms of Reference for a United Nations Framework Convention on International Tax Cooperation

19 Jul 2024

ICAP Documentation Requirements: Selection Documentation Package Templates

18 Jul 2024

The EU as a Tax Harmonisation Catalyser – Triumphs and Challenges within an Asymmetric Cooperation Model

17 Jul 2024

Considerations Relating to CFC Stock Ownership and Allocation of Subpart F Income

17 Jul 2024

Considerations for Reforming the U.S. Source of Income Rules

16 Jul 2024