[BOOK][B] Taxing profit in a global economy

MP Devereux, AJ Auerbach, M Keen, P Oosterhuis… - 2020 - books.google.com
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 …

One answer to why and how to tax the digitalized economy

W Schön - Intertax, 2019 - kluwerlawonline.com
The question of why and how to tax the digitalized economy has been at the top of the
international tax policy debate since the inception of the BEPS Action Plan in 2013. Over the …

Residual profit allocation by income

MP Devereux, AJ Auerbach, M Keen, P Oosterhuis… - 2019 - papers.ssrn.com
This paper is a draft chapter of a forthcoming book on the taxation of international business
profit by the authors of this paper, to be published by Oxford University Press. The group has …

Full Taxation: The Single Tax Emperor's New Clothes

L Parada - Fla. Tax Rev., 2020 - HeinOnline
It has recently been argued in the international tax literature that the OECD Base Erosion
and Profit Shifting project (BEPS) reflects and effectuates full taxation, namely an …

The EU Anti-Tax Avoidance Directive and the Base Erosion and Profit Shifting (BEPS) Action Plan: necessity and adequacy of the measures at EU level

G Ginevra - Intertax, 2017 - kluwerlawonline.com
The article scrutinizes the recently adopted Directive 2016/1164/EU (also known as the Anti-
Tax Avoidance Directive) in the light of BEPS Actions 2, 3 and 4. For this particular purpose …

Assessing the tax benefits of hybrid Arrangements—evidence from the Luxembourg Leaks

I Hardeck, PU Wittenstein - National Tax Journal, 2018 - journals.uchicago.edu
Using the Luxembourg Leaks database, we study how multinational firms avoid taxes via
hybrid arrangements and assess their corresponding tax benefits. Confidential tax rulings …

Hybrid Mismatch Arrangements-A Myth or a Problem That Still Exists?

C Kahlenberg, A Kopec - World Tax J., 2016 - HeinOnline
Under the principle of financial freedom, every company is generally free to decide what
kind of capital would primarily be used to finance the company's activities. In addition to the …

[BOOK][B] Hybrid financial instruments in international tax law

J Bundgaard - 2016 - books.google.com
Financial innovation allows companies and other entities that wish to raise capital to choose
from a myriad of possible instruments that can be tailored to meet the specific business …

[PDF][PDF] Neutralizing effects of hybrid mismatch arrangements

P Harris - Papers on Selected Topics in Protecting the Tax Base …, 2014 - un.org
Papers on selected topics in protecting the tax base of develo** countries are preliminary
documents for circulation at the “Workshop on Tax Base Protection for Develo** …

[BOOK][B] Banking on Failure: Cum-ex and why and how Banks Game the System

RS Collier - 2020 - books.google.com
Banks seem all too often involved in cases of misconduct, particularly involving the
exploitation of tax systems. Banking on Failure explains why and how banks" game the …