Fresh Ideas Emerge for New EU Budget Levies

This article evaluates the practical and theoretical difficulties of implementing formulary apportionment in international taxation, particularly the challenges of estimating appropriate allocation factors across jurisdictions. It contributes to ongoing debates about alternatives to arm’s length pricing in a BEPS-influenced environment.

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This paper analyzes the unintended consequences of the Undertaxed Profits Rule under Pillar Two, including compliance burdens, allocation distortions, and enforcement complexity. It raises concerns about how the rule operates in practice across jurisdictions with differing tax regimes.

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This study examines how differences in regional tax policies influence migration decisions within Canada, highlighting behavioral responses to subnational tax variation. The findings have broader implications for tax competition and mobility in multi-jurisdictional systems.

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This paper evaluates how international trade transmits climate-related economic damages across regions, using a structural gravity framework. It provides insight into cross-border externalities and raises important considerations for tax and policy instruments addressing climate change.

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This paper examines how corporate tax systems interact with the growing importance of data centers, focusing on jurisdictional allocation of profits and the challenges digital infrastructure poses for traditional nexus and sourcing rules. It highlights broader implications for international tax policy as economies become increasingly data-driven.

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 Citation: Avi-Yonah, Reuven S., Corporate Taxation And Data Centers (April 04, 2026). U of Michigan Law & Econ Research Paper Forthcoming

This paper examines the interaction between environmental policy and international trade law, focusing on the EU’s Carbon Border Adjustment Mechanism (CBAM). It analyzes how CBAM may function as a de facto tax on imports and evaluates its compatibility with WTO non-discrimination principles. The piece highlights tensions between climate policy and global trade obligations, raising implications for cross-border tax policy and enforcement. It is particularly relevant for understanding how environmental measures can reshape international tax and trade frameworks.

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This paper examines how carbon taxation interacts with executive compensation structures tied to ESG performance metrics. It highlights how environmental tax policies influence firm-level incentives and cross-border corporate behavior. The analysis is relevant to international tax discussions as carbon taxes increasingly function as quasi-border adjustments and interact with global tax coordination efforts. It contributes to broader debates on how tax systems incorporate sustainability objectives and affect multinational decision-making.

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This study examines how firms and economies adjust over time to trade shocks, including tariffs and global supply disruptions. It provides empirical evidence on how trade policy changes influence production, investment, and cross-border economic activity. The findings are relevant to international tax policy because trade shocks often trigger changes in profit allocation, transfer pricing strategies, and jurisdictional tax bases. The paper helps contextualize how tax systems respond to shifting global trade dynamics.

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This paper evaluates the administrative and compliance burdens associated with the OECD’s Pillar Two global minimum tax regime. Through qualitative analysis, it highlights the complexity multinational enterprises face in implementing new reporting and calculation requirements. The study raises concerns about disproportionate compliance costs relative to expected revenue gains. It contributes to ongoing discussions about the practicality and efficiency of global minimum tax rules in international tax policy.

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This study explores the administrative and compliance costs associated with implementing Pillar Two’s global minimum tax regime. It highlights the disproportionate burden on multinational enterprises and tax authorities, raising questions about efficiency and long-term enforceability.

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