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The Interaction Between the UTPR and Tax Treaties: Selected Issues

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Papers & Reports
The Interaction Between the UTPR and Tax Treaties: Selected Issues

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The Interaction Between the UTPR and Tax Treaties: Selected Issues

09 Jan 2025

Substantive Tax Sovereignty Under Globalization

07 Jan 2025

Sustainable tax governance: a shared responsibility

06 Jan 2025

International Tax Reform: Release of New Tools for the Implementation of Amount B Relating to the Simplification of Transfer Pricing Rules

19 Dec 2024

Harmful Tax Practices – 2023 Peer Review Reports on the Exchange of Information on Tax Rulings

16 Dec 2024

Dos the U.S. Have to be a Tax Haven?

12 Dec 2024

The Unintended Consequences of Global Tax Asymmetries on Foreign Risk-Taking

19 Nov 2024

2023 Mutual Agreement Procedure Statistics

15 Nov 2024

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

The Global Minimum Tax and Special Economic Zones

16 Jul 2024

International Tax and International Law Revisited

11 Jul 2024

Can Investment Treaties Defeat Pillar 2

11 Jul 2024

Corporate Tax Statistics

11 Jul 2024

Principles Justifying the Reallocation of Taxing Rights to Market Jurisdictions: Do We Need Them?

11 Jul 2024

Considerations for Reforming the U.S. Transfer Pricing Rules

09 Jul 2024

Qualified Status under the Global Minimum Tax: Questions and Answers

17 Jun 2024

Tax Challenges Arising from the Digitalisation of the Economy –Administrative Guidance on the Global AntiBase Erosion Model Rules (Pillar Two), June 2024

17 Jun 2024

Broadening the Gains from Generative AI: The Role of Fiscal Policies

17 Jun 2024

A Toss Up? Comparing Tax Revenues from the Amount A and Digital Service Tax Regimes for Developing Countries

10 Jun 2024

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

07 Jun 2024

International Compliance Assurance Programme (ICAP) Frequently Asked Questions

04 Jun 2024

A Scrap Game: Impacts of the EU Carbon Border Adjustment Mechanism

03 Jun 2024

2024 Progress Report on Tax Co-operation for the 21st Century

24 May 2024

Taxation and the Realisation of Socioeconomic Rights in Africa: What Is the Role of International Cooperation?

15 May 2024

The Role of the Investor Motive in the Effectiveness of Tax Incentives: Evidence for FDI Location in Indonesia

13 May 2024

Tax Hybridity and the Globalization of Taxation: Convergence, Borrowing, Culture

01 May 2024

A Global Minimum Tax for Large Firms Only: Implications for Tax Competition

26 Apr 2024

Detecting Cross-Border Transaction Patterns Using Machine Learning: The Case of Indonesia

25 Apr 2024

Tax Challenges Arising from the Digitalisation of the Economy – Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2023)

25 Apr 2024

Profit-Shifting Elasticities, Channels, and the Role of Tax Havens: Evidence from Micro-Level Data

22 Apr 2024

Import Competition and U.S. Sentiment Toward China

22 Apr 2024

The Design of a UN Framework Convention on International Tax Cooperation

22 Apr 2024

Taxation of Autonomous Artificial Intelligence: Socially Sustainable Expansion of Automation and Impacts on International Tax

15 Apr 2024

Tax Treaties and Denizenship Based Tax Systems

11 Apr 2024

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

04 Apr 2024

Tax Treaties and Income Shifting

04 Apr 2024

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

01 Apr 2024

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

28 Mar 2024

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

21 Mar 2024

Efficient Economic Rent Taxation Under a Global Minimum Corporate Tax

20 Mar 2024

Promoting Inclusive and Effective Tax Cooperation at the United Nations

16 Mar 2024

Case Law Trend: Withholding Taxation Under the Fundamental Freedoms

14 Mar 2024

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

09 Mar 2024

Tax Transparency in Africa 2024: Africa Initiative Progress Report

06 Mar 2024

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

05 Mar 2024

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

05 Mar 2024

Business model digitalization, competition, and tax savings

01 Mar 2024

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

01 Mar 2024

Understanding the Impact of OECD BEPS Actions on Double Tax Treaties

29 Feb 2024

The Untold Tale of a Tax Rulings Haven

29 Feb 2024

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

28 Feb 2024

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

28 Feb 2024

Pillar One - Amount B

19 Feb 2024

Cryptocurrency Investments and Taxation: Analyzing Global Responses by Tax Authorities

18 Feb 2024

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

13 Feb 2024

Deterrence and Displacement in Offshore Trade: Evidence from the Panama Papers Leak

13 Feb 2024

The consequences of the 2017 US international tax reform: a survey of the evidence

03 Feb 2024

Whither LOB?

02 Feb 2024

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

30 Jan 2024

Tax It Before Exit: Exit Taxation and Greenfield Investments

26 Jan 2024

The UTPR and the Treaties

10 Jan 2024

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

10 Jan 2024

Corporate income tax, IP boxes and the location of R&D

10 Jan 2024

The Global Minimum Tax and the taxation of MNE profit

09 Jan 2024

Taxing Digital Platforms

03 Jan 2024

Frequently Asked Questions on Pillar 2 Directive

26 Dec 2023

Are Consumers Paying the Bill? How International Tax Competition Affects Consumption Taxation

23 Dec 2023

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

22 Dec 2023

Financial Constraints and Tax Planning: International Evidence

20 Dec 2023

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

18 Dec 2023

Destination Taxation of Corporate Income and the Emerging Implications

05 Dec 2023

Tax In History: CFCs and Tax Treaties: Historical Elements for the IIR Debate

30 Nov 2023

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

29 Nov 2023

Corporate Tax System Complexity and Investment

27 Nov 2023

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

21 Nov 2023

Corporate Tax Statistics 2023

21 Nov 2023

International Tax Policy's Harm to Manufacturing and National Interests

01 Nov 2023

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

01 Nov 2023

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

31 Oct 2023

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

31 Oct 2023

Global Tax Evasion Report 2024

23 Oct 2023

Profit Shifting Under the Arm’s Length Principle

19 Oct 2023

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

12 Oct 2023

Minimum Tax Implementation Handbook (Pillar Two)

11 Oct 2023

The Multilateral Convention to Implement Amount A of Pillar One

11 Oct 2023

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

11 Oct 2023

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

03 Oct 2023

Simplified Application of the Arm’s Length Principle for Baseline Distribution Functions offers win/win for MNEs and Tax Authorities - A Risk Management Perspective on the OECD Amount B Proposal

02 Oct 2023

Government Reputation, FDI, and Profit-shifting

02 Oct 2023

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

02 Oct 2023

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

02 Oct 2023

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

28 Aug 2023

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

28 Aug 2023

UN MTC Article 14: The Mistaken Retention

28 Aug 2023

Global Tax Hubs

28 Aug 2023

Strategic Narratives in International Tax Policy Making: Beps Action 1 and the Stability Argument

22 Aug 2023

Can the OECD Author an Equitable International Tax Architecture?

22 Aug 2023

Transfer Price Documentation Rules and Multinational Firm Behavior - Evidence from France

22 Aug 2023

A Macroeconomic Perspective on Taxing Multinational Enterprises

15 Aug 2023

The Fundamentals of Tax Incentives

08 Aug 2023

Promotion of inclusive and effective international tax cooperation at the United Nations

26 Jul 2023

The Use and Abuse of Location-Specific Rent

25 Jul 2023

Progressive Formulary Apportionment: The Case for 'Amount D'

25 Jul 2023

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

17 Jul 2023

The Influence of Macroeconomic Growth Opportunities on U.S. Effective Tax Rates on Foreign Earnings

17 Jul 2023

Pillar 2 and the Credits

10 Jul 2023

The Legitimacy Of The OECD’s Work On Pillar Two: An Analysis Of The Overconfidence In A ‘Devilish Logic’

10 Jul 2023

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

10 Jul 2023

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

19 Jun 2023

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

19 Jun 2023

Pillar 2 and the Bits

15 Jun 2023

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

07 Jun 2023

Unitary Taxation After Pillar One

25 May 2023

Tax Implications of Contributing Appreciated Property Overseas

22 May 2023

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

22 May 2023

Implementing Pillar Two: Potential Conflicts with Investment Treaties

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

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)

27 Mar 2023

Taxing Zero

27 Mar 2023

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

27 Mar 2023

Optimal Taxation of Multinational Enterprises: A Ramsey Approach

27 Mar 2023

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

27 Mar 2023

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

14 Mar 2023

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

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

An Indonesian Perspective on Global Tax Reform and Pillar 2

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

Education

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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