Showing 37 - 48 of 68 publications

Global distribution of revenue loss from tax avoidance – Re-estimation and country results

by Alex Cobham & Petr Janský

International corporate tax is an important source of government revenue, especially in lower-income countries. An important recent study of the scale of this problem was carried out by International Monetary Fund researchers Ernesto Crivelli, Ruud De Mooij, and Michael Keen. We first re-estimate their innovative model, and then explore the effects of introducing higher-quality revenue…

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February 2017

Taxing Multinational Enterprises as Unitary Firms

by Sol Picciotto ed.Sol Picciotto

The international tax system needs a paradigm shift. The rules devised over 80 years ago treat the different parts of a multinational enterprise as if they were independent entities, although they also give national tax authorities powers to adjust the accounts of these entities. This creates a perverse incentive for multinationals to create ever more…

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February 2017

Tax Base Erosion and Profit Shifting in Africa – Part 2: A Critique of Some Priority OECD Actions from an African Perspective

by Annet Wanyana Oguttu

In Part 2 of this article, the author continues her examination of the implications of the OECD’s Action Plan on Tax Base Erosion and Profit Shifting from an African perspective. Although the OECD Project covers 15 Actions to address BEPS, the low economic development of many African countries, their limited administrative capacity and general lack…

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January 2017

Transfer Pricing in Argentina 1932-2015

by Veronica Grondona & Andres Knobel

This document provides a review of the Argentine tax authority’s structure for dealing with transfer pricing in Argentina; a chronological review of the legislative transfer pricing framework; and a very extensive listing of the transfer pricing cases that have reached different court levels. The document also summarises some of the difficulties encountered in relation to…

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January 2018

Improving International Tax Dispute Settlement

by Sol Picciotto

This ICTD Research in Brief is a two-page summary of ICTD Working Paper 55 by Sol Picciotto. This series is aimed at policy makers, tax administrators, fellow researchers and anyone else who is big on interest and short on time. This paper examines: what international tax disputes are; the growth of such disputes; causes and solutions; and offers suggestions…

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December 2016

What Have We Learned About International Tax Disputes

by Sol Picciotto

This Briefing summarises ICTD Working Paper 55, which examines the Mutual Agreement Procedure (MAP) for tax authorities to resolve their differences over the interpretation of tax treaties. It surveys available evidence on reasons for the increase in such conflicts, and analyses proposals for improving the MAP, especially mandatory binding arbitration. Despite the shift to arbitration…

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August 2016

International Tax Disputes: Between Supranational Administration and Adjudication

by Sol Picciotto

The proposals resulting from the G20/Organisation for Economic Cooperation and Development (OECD) project on Base Erosion and Profit Shifting (BEPS) include a drive for mandatory binding arbitration of international tax disputes, strongly supported by business. This issue should be considered in the context of the reasons for and nature of international tax disputes. The bulk…

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June 2016

Tax Base Erosion and Profit Shifting in Africa – Part 1: Africa’s Response to the OECD BEPS Action Plan

by Annet Wanyana Oguttu

This paper considers what Africa’s response should be to the OECD’s base erosion and profit shifting (BEPS) project. The paper acknowledges that BEPS concerns for developing countries (such as those in Africa) may not necessarily be the same as those for developed countries. The author first explains the concepts of tax avoidance and tax planning,…

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June 2016

Taxing Multinational Enterprises as Unitary Firms

by Sol Picciotto

This paper explores the issues raised for international tax rules of explicitly treating multinational enterprises (MNEs) as single or unitary firms. It first briefly explains why reform of international corporate taxation is important particularly for developing countries, then outlines the flaws in the current system. It discusses the impetus created for reforms, and the political…

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May 2016

International Corporate Taxation

by Sol Picciotto

This ICTD Summary Brief is the third in our six special research synthesis pieces, produced at the end of the ICTD’s first five-year funding period in Spring 2016. This one looks at international corporate taxation.

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