Showing 61 - 68 of 68 publications
February 2015

The Tax Policy Outlook for Developing Countries: Reflections on International Formulary Apportionment

by Michael C. Durst

The author offers a retrospective analysis of his recently-completed extensive research on the technical feasibility of international formulary apportionment of corporate taxable income, as a replacement for the body of ‘arm’s-length’ transfer pricing rules generally in use around the world. In this retrospective analysis the author considers recent analytical work on base erosion and profit…

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January 2015

Global Taxes and International Taxation: Mirage and Reality

by Richard M. Bird

Many global taxes have been proposed over the years. This study reviews the more important global tax proposals and concludes that, while many such ideas seem inappropriate or inadequately thought through, others are worth taking seriously. In reality, however, no global governance structure to impose such taxes exists or is likely to emerge in the…

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November 2014

International Distribution of the Corporate Tax Base: Implications of Different Apportionment Factors under Unitary Taxation

by Alex Cobham & Simon Loretz

Under the current system of separate accounting, tax-motivated international profit shifting results in misalignment of profits and real economic activity. While the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting initiative aims to measure and curtail this, critics claim serious progress is only possible with greater emphasis on formulary apportionment methods…

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November 2014

Unitary Taxation and International Tax Rules

by Reuven Avi-Yonah & Zachée Pouga Tinhaga

Any proposal for adoption of a unitary tax (UT) system ought to clear the first and most common hurdle of its compatibility, or lack of it, with the current norms in the international tax system – specifically, the current tax treaty network. This paper argues that unitary taxation is compatible with most of the current…

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November 2014

Unitary Taxation of the Finance Sector

by Kerrie Sadiq

Multinational financial institutions (MNFIs) play a significant role in financing the activities of their clients in developing nations. Consistent with the ‘follow-the-customer’ phenomenon which explains financial institution expansion, these entities are increasingly profiting from activities associated with this growing market. However, not only are MNFIs persistent users of tax havens, but also, more than other…

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June 2014

Beyond BEPS: A Tax Policy Agenda for Developing Countries

by Michael C. Durst

As the Organisation for Economic Co-operation and Development (OECD) moves to the final stages of its work on base erosion and profit shifting (BEPS), this paper reflects on the most promising directions for legislative changes and other action which developing countries might take to protect their corporate tax bases. The paper observes that the barriers…

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September 2013

Is the International Tax System Fit for Purpose, Especially for Developing Countries?

by Sol Picciotto

Taxes are a basis of national states, but they have been internationally coordinated since the emergence of taxes on income and profits, which were central to the legitimacy of taxation and the increased power of states in the 20th century. This paper traces the historical development of this international system, especially in relation to its interaction…

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