The international tax system is in dire need of reform. It allows multinational companies to
shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major …

Transfer pricing for tax purposes has long been contentious, but recent political and public
concerns about tax avoidance have energised critiques of current rules and debates about …

We show that US multinationals record sales and the profits from these sales in tax havens
while their goods and services are physically sold in other countries. We propose a …

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 …

Cloud computing has fundamentally changed how companies operate. Companies have
quickly adapted by moving their businesses to the cloud, but international tax standards …

Research Highlights and Abstract Contextualises and clarifies the case for unitary taxation In
so doing sets out the structural and institutional constraints of the current system of taxation …

Why do States enact transfer pricing legislation? While originally conceived as an
antiavoidance mechanism, transfer pricing and related debates have gradually moved …

In recent decades, market power has increased substantially, according to multiple
measures that describe industry concentration, mark-ups, and business profitability. While …

The purpose of this article is to describe a mechanism for taxing e-commerce profits of
multinational corporations (MNCs). Our research hypothesis is that the new economic …

GETTING SERIOUS ABOUT CROSS-BORDER. EARNINGS STRIPPING: ESTABLISHING AN
ANALYTICAL FRAMEWORK* Page 1 GETTING SERIOUS ABOUT CROSS-BORDER …