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The Pillar Two Regime in the Post-Implementation Era: Structural Mechanics and Geopolitical Fragmentation (2026)

13 Jan 2026

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Pramod Kumar Siva

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The Pillar Two Regime in the Post-Implementation Era: Structural Mechanics and Geopolitical Fragmentation (2026)

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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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The Pillar Two Regime in the Post-Implementation Era: Structural Mechanics and Geopolitical Fragmentation (2026)

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

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EU State Aid and the Tax Allocation of Multinationals' Profits

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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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Can the OECD Author an Equitable International Tax Architecture?

22 Aug 2023

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

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A Macroeconomic Perspective on Taxing Multinational Enterprises

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Progressive Formulary Apportionment: The Case for 'Amount D'

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

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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

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

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Designing Domestic Minimum Taxes in Response to the Global Minimum Tax

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

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

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An Indonesian Perspective on Global Tax Reform and Pillar 2

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

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04 May 2017

Coordination of Transfer Prices on Intra-Firm Trade

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

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Corporate Inversions and Economic Performance

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2014 ITPF Competitiveness Index_20140224b

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

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

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

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ITPF Competitiveness Index 2013

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ITPF Competitiveness Index 2012

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

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

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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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