My last attempt at a review of recent academic literature on a corporate tax income topic was well-received, so here’s round two in the “Are firms really…?” series. This time, I’ll take a look at another paper out of Oxford University in the context of an existing body of literature. Here, we are looking at […]

Are multinational groups headquartered in the United States more aggressive in their tax planning compared to non-US competitors? That is, at least, a very popular strapline in tax circles. Negative media stories about the tax affairs of major US firms such as Apple, Amazon and Starbucks are often described as contributing factors to the OECD/G20 […]

International tax cooperation is hard. Especially when it challenges national sovereignty. Sovereignty is close to heart for politicians. Taxation remains a cornerstone of the nation-state and of the social contract. Governments are not liable to relinquish absolute authority on tax matters. So, at least, the story goes. Indeed, the reality – and the associated perception – of taxation […]

Are taxes on corporations business costs or intra-economy transfers? This is a oft-discussed question in debates about corporation taxes – academic, political as well as layman debates. And it is one with significant implications for tax policy. This blog is here to say: Both. Possibly. But mostly a transfer. The fiscal coin and taxes as […]

Since the first number value systems were invented around 3400 BC, numbers have played a central role in human society. Arguably, though, they have never been more important than they are today. We fiend for data, quantities, statistics and numbers to an astounding degree. We live in an almost fetishised data-heavy society. This applies to the tax […]

Hey, ho. Another month, another exotic tax haven leak. Another political storm, another media circus, another rush to condemn. And maybe this time, it will lead to lasting change. Who knows? But my guess is the Bahama Leaks won’t quite live up to whatever hype it has attracted in its short life. There are two […]

While the storm is raging in wake of the European Commission’s decision in its state aid investigation of Apple’s Irish tax structure, and while we wait for the 130 page decision documentation, here is a log of my thoughts on the issues: 1) This is historic Before any more analytical thoughts, I must remark that […]

The corporate income tax is under pressure. A host of factors have contributed to economic, normative and political discussions on the need for corporate income taxation and its role in the architecture of national and international tax systems. Among the most persistent calls today is the lowering or scrapping of corporate income tax (CIT) altogether. And […]

For the longest time, international law has treated multinational enterprises (MNEs) as consisting of separate, independent units, rooted in separate national jurisdictions. Apple’s US corporate headquarters is distinct from its Irish holding company, which is distinct from its local national subsidiaries – even though they are all part of the same multinational group. Their reporting compliance and tax liabilities are, […]

One of the major 21st century challenges for politicians and polities at both the national, regional and international levels is the governance of ever-more global, mobile and flexible economic and financial flows. No more so than in the area of taxation, which looks likely to remain the last bastion of entrenched perceptions of national sovereignty, an undisputed cornerstone […]