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Differing Abuse Concepts in Double Tax Conventions: At What Level and to What Extent Can Equality Be Realized?

2022
2023

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Differing Abuse Concepts in Double Tax Conventions: At What Level and to What Extent Can Equality Be Realized?

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Doron Narotzki, Tamir Shanan

22 May 2023

Implementing Pillar Two: Potential Conflicts with Investment Treaties

22 May 2023

Mandatory Binding Dispute Resolution in the Base Erosion and Profit Shifting (BEPS) Two Pillar Solution

22 May 2023

Challenges at the intersection between investment provisions in regional trade agreements and implementation of the GloBE Rules under Pillar Two

20 May 2023

Intellectual Property and Tax Incentives: a Comparative Analysis of the EU and the US Legal Frameworks

20 May 2023

The Mirage of Mobile Capital

19 May 2023

Who Really Matters in Corporate Tax?

19 May 2023

Differing Abuse Concepts in Double Tax Conventions: At What Level and to What Extent Can Equality Be Realized?

19 May 2023

A Global Climate Wealth Tax to Fund a Worldwide, Just Transition

19 Apr 2023

The Irish Apple Tax Disaster

19 Apr 2023

Public Finance in the Real World: Through the Lens (Down the Rabbit Hole?) of Transfer Pricing

03 Apr 2023

The Global Corporate Minimum Tax: A Cure or Not?

03 Apr 2023

Does the 'Initial Phase Relief' Make the EU’s Pillar Two Directive Invalid?

03 Apr 2023

Follow the Money: Why is International Tax Bilateral

27 Mar 2023

Taxing Multinationals: Three Lenses on International Tax Cooperation (Comments on UN Resolution 77/244, Promotion of Inclusive and Effective International Tax Governance at the United Nations)

27 Mar 2023

U.S. International Tax Policy and Corporate America

27 Mar 2023

Taxing Intellectual Property Assets on a Cross-Border Transaction: Application of Mobilia Sequuntur Personam and the Case of the India–Mauritius Tax Treaty

27 Mar 2023

Taxation of Information and the Data Revolution

27 Mar 2023

Why 15%? Justifying the Global Corporate Minimum Tax

27 Mar 2023

Never-Ending Battle Between Privacy and Transparency: The Case of Registers of Beneficial Ownership Before the CJEU

27 Mar 2023

Crossing the Atlantic: The role of U.S. executives in tax planning of foreign subsidiaries

27 Mar 2023

Optimal Taxation of Multinational Enterprises: A Ramsey Approach

27 Mar 2023

Testimony for the Hearing “Cross-border Rx: Pharmaceutical Manufacturers and U.S. International Tax Policy”

27 Mar 2023

Taxing Zero

27 Mar 2023

The Canadian Digital Services Tax

22 Mar 2023

The Retained EU Law (Revocation and Reform) Bill - Could the UK VAT System Operate Without EU Law?

20 Mar 2023

Designing Domestic Minimum Taxes in Response to the Global Minimum Tax

20 Mar 2023

The Effects of the Tax Cuts and Jobs Act on the Tax-Competitiveness of Multinational Corporations

20 Mar 2023

The Physical, Human Driven Digital Economy: The Overvaluation of Intangibles and its Effects on Tax and Society

20 Mar 2023

General Explanations of the Administration's Fiscal Year 2024 Revenue Proposals

14 Mar 2023

Trade Enforcement Tools and International Taxation: A Digital Services Tax Case Study

13 Mar 2023

An Indonesian Perspective on Global Tax Reform and Pillar 2

13 Mar 2023

Foreign Holding Companies and the US Taxation of Foreign Earnings: Evidence from TIPRA 2005

13 Mar 2023

The effect of US tax reform on the taxation of US firms’ domestic and foreign earnings

13 Mar 2023

Tax Challenges Arising from the Digitalisation of the Economy – Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two)

08 Mar 2023

Pillar 2, Fiat, and the EU Unanimity Rule on Tax Matters by Rita de la Feria

06 Feb 2023

Test 01

01 Feb 2022

Impact of Tax on Foreign Direct Investment

04 May 2017

Coordination of Transfer Prices on Intra-Firm Trade

04 May 2017

The Effect of IP Box Regimes on International IP Payments and Foreign Research and Development

30 Aug 2016

Cross-Country Evidence on the Preliminary Effects of Patent Box Regimes on Patent Activity and Ownership

01 Oct 2015

Corporate Inversions and Economic Performance

08 Sep 2015

ITPF Competitiveness Index 2015

17 Mar 2015

2014 ITPF Competitiveness Index_20140224b

25 Feb 2014

1995-2011 List of Research Papers

19 Feb 2014

Offshoring high-skilled jobs: EU multinationals and domestice employment of inventors

19 Feb 2014

The Intertemporal Substitution and Income Effects of GST Rate Increases: Evidence from New Zealand

19 Feb 2014

What Do We Know About Base Erosion and Profit Shifting? A Review of the Empirical Literature

11 Jan 2014

International Implications of Corporate Tax Rate Reductions

29 Mar 2013

ITPF Competitiveness Index 2013

01 Feb 2013

ITPF Competitiveness Index 2012

08 Feb 2012

The Effects Of The Taxation of Dividends on the Allocation of Foreign Portfolio Investment Around the World

01 Nov 2010

A Comparison of the Tax-motivated Income Shifting of Multinationals in Territorial and Worldwide Countries

01 Nov 2010

Where in the World Are "Permanently Reinvested" Foreign Earnings?

30 Jun 2010

Cross-Country Comparisons of Corporate Tax Systems

22 Mar 2010

The Consequences of Territorial and Worldwide Systems of International Taxation

01 Oct 2009

Investor Taxation in Open Economics

01 Aug 2009

Book-Tax Conformity: Implications for Multinational Firms

30 Mar 2009

Corporate Income Tax Burdens at Home and Abroad

30 Jan 2009

Closer Economic Integration and Corporate Tax Systems

01 Jun 2008

Expansion Abroad and the Domestic Operations of U.S. Multinational Firms

25 Sep 2003

"Taxing Multinationals," International Tax and Public Finance

01 Aug 2003

Does Acquisition by Non-U.S. Shareholders Cause U.S. Firms to Pay Less Tax

01 Jun 2003

The Effect of the Tax Reform Act of 1986 on the Location of Assets in Financial Services Firms

01 Jun 2002

Structural Estimates of Factor Substituition from Firm-Level Panel Data on Multinational Corporations

19 Feb 1999

Taxes and Cross-Border Investments: The Empirical Evidence

04 Jan 1999

What Do We Know About The Impact of Offshore Investment On The U.S. Economy

01 Jun 1996

The Compliance Cost of Taxing Foreign-Source Income: Its Magnitude, Determinants, and Policy Implications

01 Jun 1996

U.S. Interest-Allocation Rules: Effects and Policy

01 Jun 1995

Corporate Domicile and Average Effective Tax Rates: The Cases of Canada, Japan, the United Kingdom, and the United States

01 Jan 1995

Free Trade Taxation And Protectionist Taxation

01 Mar 1994

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