OECD

ABSTRACT This paper assesses national and international responses to tax challenges presented by cross-border electronic commerce. Ten years after these challenges were first identified, a survey of national government reactions shows that many countries have not passed any significant tax legislation or administrative guidance with respect to the taxation of global e-commerce. This lack of action at the national level...

Abstract Tax havens have attracted increasing attention from policymakers in recent years. This paper provides an overview of a growing body of research that analyzes the consequences and determinants of the existence of tax haven countries. For instance, recent evidence suggests that tax havens tend to have stronger governance institutions than comparable nonhaven countries. Most importantly, tax havens provide opportunities...

In 1998, the Organisation for Economic Co-operation and Development (OECD) issued a report titled “Harmful Tax Competition—An Emerging Global Issue” (14).  In this report, the OECD sought to “define what harmful tax competition was, to make an argument for just why it was harmful, and to set out a response to the problem” (42).  In reality, the OECD proposed two different responses to the “problem,” based...

Reuven S. Avi-Yonah[1] Kimberly A. Clausing[2] 1. Introduction The general purpose of tax treaties is to implement the consensus underlying the international tax regime by shifting the right to tax passive income from the source to the residence country, and by limiting the ability of source countries to tax active income to income attributable to a permanent establishment.[3] Article 7 of the OECD MC implements...

In a world where authorities are being given more powers to investigate various crimes, the situation also arises where some representatives of these authorities will attempt to abuse their powers. In other instances, the powers are used without proper thought going into the purpose behind the powers, and without the checks and balances that should be introduced by administrators to ensure that abuses do not take place....

The OECD has proposed amendments to its Model Tax Convention and Commentary that would establish a system for the mandatory arbitration of tax disputes between two treaty countries when the tax officials of those countries have been unable to resolve those disputes within a two-year period.[1] The proposal is undoubtedly well-meaning and does address a small but significant problem - the "rare cases" (OECD characterization)[2]...

Introduction This work examines the primary features of how partnerships are generally taxed in terms of international law and convention where partnerships conduct cross-border transactions. The OECD Double Tax Convention influences the treatment of the partnerships. I. Differences that Affect the Tax Treatment of Partnerships The OECD states in the work entitled: Model Tax Convention on Income and On Capital,...