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Tax Compliance Costs of Pillar Two – A Qualitative Study

30 Mar 2026

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Sarah Daxenberger

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Tax Compliance Costs of Pillar Two – A Qualitative Study

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Impact of Environmental Measures on International Trade (with focus on EU CBAM & WTO law)

03 Apr 2026

Carbon Taxes and ESG Compensation

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Dynamic Adjustment to Trade Shocks

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Tax Compliance Costs of Pillar Two – A Qualitative Study

30 Mar 2026

OECD Pillar Two and U.S. GILTI: Comparative Analysis and Policy Implications for Multinational Tax Compliance

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The Sovereignty Paradox: Digital Services Taxes, Political Jurisprudence and the Limits of State Power in the Digital Economy

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How the U.S. Constitution Shapes International Tax Law: Instrument Choice in Tax Agreements

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Digital Services Taxes and the WTO

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International Tax Reform and Multinational Corporate Behavior: Conceptual Insights from the One Big Beautiful Bill Act

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Fiscal Limits to Protectionism: The 2025 U.S. Tariff Laffer Curve

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Hidden Profits, Lost Jobs? Tax Havens and Employment Decisions

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What is the Share of U.S. Tariffs Paid by Exporters?

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The “Hidden Sides” of the Taxation of Dividends and Interest for Corporate America versus Corporate Europe

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Tariffs and Firm Expectations

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From Physical Presence to Digital Participation Toward a Participation-Based Nexus Doctrine in State Taxation

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Options for a Protocol on Services under the UN Framework Convention on International Tax Cooperation

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Tax Incentives for Nigerian Oil and Gas Companies under the Nigeria Tax Act

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The Controlled U.S. Corporate Footprint by Owner Jurisdiction: Evidence from IRS SOI Data (2002–2022)

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Uneven State-Level Exposure to Potential U.S. Tariff Disputes with Canada and Mexico

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A Leak in Paradise: Reputation Repair Policies After Offshore Data Leaks

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The Definition and Application of the Separate-Entity Approach in the OECD Transfer-Pricing Guidelines

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Australian Tax Treaty Policy: The Dilemma of a Wealthy Capital-Importing Nation

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Income Shifting from Transfer Pricing: Further Evidence from Tax Return Data by

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Withholding Taxes in Developing Countries: Relief Method and Tax Sparing in Tax Treaties with OECD Members

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Taxing Mobile Money: Theory and Evidence

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Pillar Two Side-by-Side Challenges of EU Law, Global Tax Governance, Sovereignty. Comments for a Rational Win-Win Path Forward

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Why EU Revenue Matters: A Case for an EU Digital Levy

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To Tariff or Not to Tariff? That is the Question (before the U.S. Supreme Court)

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Beyond Economic Allegiance

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Effects of the Global Minimum Tax on German Corporations

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IFA Central Report: Improper Use of Tax Treaties and Source Taxation: Policy, Practice and Beyond

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Recent Developments in the Taxation of Cross-Border Services: LATAM Position(s) on the UN Terms of Reference (ToR)

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Making America Great Again? The Economic Impacts of Liberation Day Tariffs

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Canada at Trade War

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Tariff Pass-Through in the Trade War: A Firm-Heterogeneity Perspective

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EU State Aid and the Tax Allocation of Multinationals' Profits

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How Canada Should Respond to the Trump Tariff

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

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Subpart F and GILTI Recommendations

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Design and Consequences of CFC and GILTI Rules: A Review and Potential Lessons for the Global Minimum Tax

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Tax Treaties and Income Shifting

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The OECD/G20 Pillar 1 and Digital Services Taxes: A Comparison

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The Digital Economy, Global Tax Reforms and Developing Countries – An Evaluation of Pillar I and Art. 12B UN Model

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Broader Border Taxes: A New Option for European Union Budget Resources

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Location, Financial and Real Effects of CFC Rules after the ATAD Implementation in the EU

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Tax Transparency in Africa 2024: Africa Initiative Progress Report

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2024 European Elections Manifesto: The Accountancy Profession’s Priorities for the EU Mandate 2024 - 2029

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Background and Analysis of the Taxation of Multinational Enterprises and the Potential Reallocation of Taxing Rights Under the OECD’s Pillar One

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International Cooperation on Tax Matters at the United Nations: A Turning Point in History?

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Understanding the Impact of OECD BEPS Actions on Double Tax Treaties

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The Untold Tale of a Tax Rulings Haven

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Exchange of Information, Tax Confidentiality, Privacy and Data Protection from an EU Perspective

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Analysis of Developments in EU Capital Flows in the Global Context (2023)

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Cryptocurrency Investments and Taxation: Analyzing Global Responses by Tax Authorities

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The Proposal for a Council Directive on Transfer Pricing: An Assessment

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Dual-residency of Companies and EU Law: Accessing Corporate Tax Directives’ Benefits After the 2017 OECD Model Tax Convention Changes in the Dual-residency Tie-breaker for Companies

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Tax It Before Exit: Exit Taxation and Greenfield Investments

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The UTPR and the Treaties

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The Tax Attractiveness of EU Locations for corporate Investments: A Stocktaking of past Developments and recent Reforms

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Macroeconomic Policy Questions: Promotion of Inclusive and Effective International Cooperation on Tax Matters at the United Nations

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Financial Constraints and Tax Planning: International Evidence

20 Dec 2023

Administrative Guidance on the Global Anti-Base Erosion Model Rules (Pillar Two), December 2023

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Destination Taxation of Corporate Income and the Emerging Implications

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Directions for International Tax Policy, A Response to Hanna and Wilson

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Corporate Tax System Complexity and Investment

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Effective tax rates of MNEs: New evidence on global low-taxed profit

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Corporate Tax Statistics 2023

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International Tax Policy's Harm to Manufacturing and National Interests

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Country-by-Country Disclosures and Firms' Internal Information Environment

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Pillar 2: QDMTT or Safe Harbour Domestic Minimum Top-Up Tax (SHDMTT)?

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‘Just BEAT It’ Do Firms Reclassify Costs to Avoid the Base Erosion and Anti-abuse Tax (BEAT) of the TCJA?

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Global Tax Evasion Report 2024

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Profit Shifting Under the Arm’s Length Principle

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The Historical Origins and Current Prospects of the Multilateral Tax Convention

12 Oct 2023

A New Scenario in International Tax Law: Two Proposals to Rethink the OECD Model in Response to the Generalization of Distance Work by Employees

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The Multilateral Convention to Implement Amount A of Pillar One

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Explanatory Statement to the Multilateral Convention to Implement Amount A of Pillar One

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Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule

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Government Reputation, FDI, and Profit-shifting

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Mutual Agreement Procedure and Foreign Direct Investments: Evidence from Firm-level Data

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Tax Arbitration and Foreign Direct Investments: A comparison between developed and developing countries

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The Effect of U.S. Tax Reform on U.S. R&D-Intensive Multinational Companies

26 Sep 2023

Enigma of the United States, Base Erosion, and the Global Minimum Tax

01 Sep 2023

Globe: The Potential Costs Of Cooperation

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Targeted Measures Against Intra-Group Debt Financing: What Needs and Design Options in Light of the ATAD, Transfer Pricing Rules, and Pillar 2?

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Tax Strategy Disclosure: A Greenwashing Mandate?

10 Jul 2023

The Effect of the Closure of the Double Irish Arrangement on the Location of U.S. Multinational Companies’ Profits

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Response to the UN Resolution A/RES/77/244 on Promotion of Inclusive and Effective Tax Cooperation at the United Nations

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Pillar I: The Marketing and Distribution Safe Harbour (MDSH) as Applicable to Licensed Manufacturers and Centralized Business Models: Does It Fulfill Its Policy Objective?

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Pillar 2 and the Bits

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Nothing New Under the Sun? The Historical Origins of the Benefits Principle

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Tax Implications of Contributing Appreciated Property Overseas

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

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

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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

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

19 May 2023

Who Really Matters in Corporate Tax?

19 May 2023

The Irish Apple Tax Disaster

19 Apr 2023

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

19 Apr 2023

The Global Corporate Minimum Tax: A Cure or Not?

03 Apr 2023

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

03 Apr 2023

U.S. International Tax Policy and Corporate America

27 Mar 2023

Limits to Competition: Strategies for Promoting Jurisdictional Cooperation

27 Mar 2023

Global Profit Shifting of Multinational Companies: Evidence from CbCR Micro Data

27 Mar 2023

Tax Policy, Investment and Profit-Shifting

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

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)

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Taxing Zero

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

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Optimal Taxation of Multinational Enterprises: A Ramsey Approach

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

27 Mar 2023

Why 15%? Justifying the Global Corporate Minimum Tax

27 Mar 2023

The Canadian Digital Services Tax

22 Mar 2023

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

20 Mar 2023

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

20 Mar 2023

Designing Domestic Minimum Taxes in Response to the Global Minimum Tax

20 Mar 2023

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

20 Mar 2023

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

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