Fresh Ideas Emerge for New EU Budget Levies

This paper evaluates the durability of the OECD’s Pillar Two global minimum tax regime in the absence of U.S. participation. It argues that structural incentives and coordinated implementation by other jurisdictions may sustain the regime regardless of U.S. policy choices.

To read the full article, click here 

This paper revisits the role of residence-based taxation in allocating taxing rights over business income in a globalized economy. It evaluates how residence principles interact with source-based rules and modern challenges such as digitalization.

To read the full article, click here

Citation: Bulletin for International Taxation 2026 (Volume 80), No. 4/5.

This paper looks at the economic relationship between the United States and China, focusing on how closely the two systems are tied together and how that shapes trade and tax decisions. It considers both the potential for cooperation and the growing risk of economic fragmentation, along with the effects on global tax coordination and multinational investment. It also discusses how rising geopolitical tensions are influencing international tax policy and cross-border economic strategy.

To read the full article, click here.

Citation: Peterson Institute for International Economics Briefing 26-2

This paper evaluates the evolution of digital economy taxation through the lens of Arthur Cockfield’s scholarship. It examines how early conceptual frameworks anticipated current challenges in taxing digital business models. The analysis is particularly relevant to ongoing OECD reforms and debates over digital services taxation.

To read the full article, click here

Citation: Forthcoming, Canadian Tax Journal (Special Issue: Tax Sovereignty in a Digital and Divided World: A Tribute to Arthur Cockfield)

This article explores the conceptual and practical challenges of taxing data as an economic asset within the international tax framework. It considers whether existing rules can capture value generated through data-driven business models and proposes potential reforms.

To read the full article, click here

This article examines whether destination countries can assert taxing rights over profits generated through digital platform-based cross-border sales. It analyzes evolving international tax principles, including destination-based taxation and the shift away from traditional source rules. The paper is particularly relevant to ongoing reforms addressing digital economy taxation and allocation of taxing rights.

To read the full article, click here.

Citation: Fei Gao and Richard Krever, ‘Can sales destinations reclaim taxing rights on profits from cross-border sales of goods on digital platforms?’ [2025](3) British Tax Review 363-385.

This paper evaluates large-scale international tax avoidance structures and questions whether certain widely used arrangements effectively amount to systemic tax fraud. It focuses on enforcement gaps in cross-border taxation and the role of governments in enabling or constraining aggressive tax planning. The analysis contributes to ongoing debates over transparency, compliance, and the limits of current international tax enforcement frameworks.

To read the full article, click here (subscription required).

This article evaluates the practical and theoretical difficulties of implementing formulary apportionment in international taxation, particularly the challenges of estimating appropriate allocation factors across jurisdictions. It contributes to ongoing debates about alternatives to arm’s length pricing in a BEPS-influenced environment.

To read the full article, click here.

This paper analyzes the unintended consequences of the Undertaxed Profits Rule under Pillar Two, including compliance burdens, allocation distortions, and enforcement complexity. It raises concerns about how the rule operates in practice across jurisdictions with differing tax regimes.

To read the full article, click here

This study examines how differences in regional tax policies influence migration decisions within Canada, highlighting behavioral responses to subnational tax variation. The findings have broader implications for tax competition and mobility in multi-jurisdictional systems.

To read the full article, click here