The Article offers a new perspective on the way international income tax has developed from its nascency, 85 years ago, to the present day. Its main claim is that, due to the lack of a clear normative tax agenda, trade considerations unduly eroded the income tax base. Such trade considerations highlight the importance of reducing tax obstacles on trade and investment to liberalize and integrate international markets. These considerations penetrated international income tax discourse during the Cold War period, when liberalizing trade was part of a broader western agenda to establish dominance through the liberalization of international markets. The Article demonstrates that the tax allocation conventions developed in the periods prior to th...
The present international tax rules are typically justified by origin-based theories. These theories...
This thesis examines the income-shifting behaviour of multinational corporations when they are facin...
The gist of this article boils down to the impact of unfair tax competition on the current state and...
The taxation of the income derived from financial assets and transactions was always a daunting blac...
This Article examines the increased use of tax incentives as weapons in the international competitio...
International tax avoidance by multinational corporations is now frontpage news. At its core, the is...
For over a century, the income tax has been the mainstay of the modern fiscal state, and has underpi...
Introduction Historically, tax policies have been elaborated to address domestic economic and social...
The conventional wisdom maintains that the emergence of the International Tax Regime since the 1920’...
Recent developments – including greater taxpayer sophistication in structuring and locating internat...
Traditionally, corporate income tax has evolved on the basis of a different tax treatment of debt an...
From its beginnings late in the 19th century, the modem state has been financed primarily by progres...
Many countries tax corporate income heavily despite the incentives that they face to reduce tax rate...
While tax competition is widely regarded as a major fiscal constraint on the welfare state, in fact,...
The integration of world capital markets carries important implications for the design and impact of...
The present international tax rules are typically justified by origin-based theories. These theories...
This thesis examines the income-shifting behaviour of multinational corporations when they are facin...
The gist of this article boils down to the impact of unfair tax competition on the current state and...
The taxation of the income derived from financial assets and transactions was always a daunting blac...
This Article examines the increased use of tax incentives as weapons in the international competitio...
International tax avoidance by multinational corporations is now frontpage news. At its core, the is...
For over a century, the income tax has been the mainstay of the modern fiscal state, and has underpi...
Introduction Historically, tax policies have been elaborated to address domestic economic and social...
The conventional wisdom maintains that the emergence of the International Tax Regime since the 1920’...
Recent developments – including greater taxpayer sophistication in structuring and locating internat...
Traditionally, corporate income tax has evolved on the basis of a different tax treatment of debt an...
From its beginnings late in the 19th century, the modem state has been financed primarily by progres...
Many countries tax corporate income heavily despite the incentives that they face to reduce tax rate...
While tax competition is widely regarded as a major fiscal constraint on the welfare state, in fact,...
The integration of world capital markets carries important implications for the design and impact of...
The present international tax rules are typically justified by origin-based theories. These theories...
This thesis examines the income-shifting behaviour of multinational corporations when they are facin...
The gist of this article boils down to the impact of unfair tax competition on the current state and...