Fresh Ideas Emerge for New EU Budget Levies

The European Parliament is considering new EU own resources that would tax online gambling, speculative real estate investment, and large companies through a turnover-based CORE contribution. The proposals expose significant legal and institutional constraints, including unanimity requirements, subsidiarity limits, especially for gambling, and unresolved questions about where digitally delivered activity should be taxed. Academic analysis warned that CORE could lead to multiple counting within corporate groups and impose tax liabilities that are disconnected from profitability, raising concerns about neutrality, legal characterization, and enforceability.  

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From Physical Presence to Digital Participation Toward a Participation-Based Nexus Doctrine in State Taxation

  • By Mansi S.Rai
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This article explores the evolution of nexus standards in U.S. state taxation from traditional physical presence to digital participation models. It analyzes how participation-based doctrines attempt to capture value creation in digital markets and considers the implications for cross-border commerce and remote sellers. The paper contributes to ongoing debates over digital nexus, economic presence standards, and the broader transformation of taxing rights in an increasingly digitalized economy.

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Options for a Protocol on Services under the UN Framework Convention on International Tax Cooperation

  • By Faith Amaro
  • By Sol Picciotto
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This paper examines potential design options for a services-focused protocol under the emerging UN Framework Convention on International Tax Cooperation. It addresses core international tax challenges in services taxation, including nexus, source rules, allocation of taxing rights, and enforcement mechanisms in a digital and cross-border economy. The authors situate the proposal within the broader shift from OECD-centered rulemaking toward a more plural multilateral architecture. For international tax practice and policy, the piece is directly relevant to ongoing debates about institutional legitimacy and the reallocation of taxing rights.

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Tax Incentives for Nigerian Oil and Gas Companies under the Nigeria Tax Act

  • By Oluwadara Ilori
  • By Peter Okediya
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This article examines the structure and policy rationale of tax incentives applicable to Nigeria’s oil and gas sector. It evaluates how incentive design affects investment behavior, revenue stability, and effective tax rates in a capital-intensive industry with significant cross-border participation. The paper also considers how domestic incentive regimes interact with multinational structuring and treaty-based relief. For international tax analysis, it offers insight into how sector-specific incentives shape cross-border investment planning.

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The Controlled U.S. Corporate Footprint by Owner Jurisdiction: Evidence from IRS SOI Data (2002–2022)

  • By Jorge A. Arroyo
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Drawing on two decades of IRS SOI data, this paper examines how foreign ownership shapes the geographic and economic footprint of U.S. corporations, with implications for international tax policy and investment regulation.

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Uneven State-Level Exposure to Potential U.S. Tariff Disputes with Canada and Mexico

  • By Wendong Zhang
  • By Ian Sheldon
  • By Seungki Lee
  • By Minseong Kang
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This paper analyzes how potential tariff disputes with Canada and Mexico would affect U.S. states unevenly, highlighting regional exposure to international trade policy shocks.

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A Leak in Paradise: Reputation Repair Policies After Offshore Data Leaks

  • By Simone Traini
  • By Katarzyna Anna Bilicka
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This paper examines how governments respond to offshore data leaks by adopting reputation repair policies, shedding light on the interaction between tax enforcement, offshore secrecy, and international compliance incentives. We examine whether the public revelation of sensitive tax information prompts firms to adopt reputation repair policies targeting shareholders. The authors investigate whether firms implicated in the leaks improve their governance, increase investor remuneration, and reorganize their activities to restore shareholder trust relative to unaffected firms. They find that, after the leaks, firms appoint more directors, especially in operations, audit, and finance and accounting, pay higher dividends, and reduce their presence in tax havens, without increasing effective tax rates. They conclude that overall, data leaks appear to change the cost-benefit trade-off of tax strategies in ways that are, on net, favorable to shareholders.

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The Definition and Application of the Separate-Entity Approach in the OECD Transfer-Pricing Guidelines

  • By Jérôme Monsenego
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This article analyzes the separate-entity principle as applied in the OECD Transfer Pricing Guidelines, exploring its theoretical foundations and practical consequences. It evaluates tensions between formal legal separateness and economic integration within multinational enterprises.

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Citation: Monsenego, Jérôme, The Definition and Application of the Separate-Entity Approach in the OECD Transfer-Pricing Guidelines, 73 Canadian Tax Journal / Revue fiscale canadienne 641 (2025).

Australian Tax Treaty Policy: The Dilemma of a Wealthy Capital-Importing Nation

  • By Richard Krever
  • By Kerrie Sadiq
  • By Na Li
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This article examines Australia’s tax treaty policy from the perspective of a capital-importing but high-income jurisdiction. It explores the tension between Australia’s interest in protecting its source-country tax base and the constraints imposed by prevailing OECD treaty norms. Through analysis of treaty practice and policy choices, the article highlights structural trade-offs faced by capital-importing countries in negotiating withholding taxes, permanent establishment thresholds, and allocation rules within the existing international tax framework.

 

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Income Shifting from Transfer Pricing: Further Evidence from Tax Return Data by

  • By Michael McDonald
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This article presents new empirical evidence on income shifting through transfer pricing using tax return data. The analysis evaluates the extent to which multinational enterprises continue to reallocate income across jurisdictions despite existing transfer pricing rules and enforcement mechanisms. The findings contribute to ongoing debates about the effectiveness of arm’s-length standards, enforcement capacity, and the empirical foundations underlying international tax reform efforts.

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Citation: McDonald, Michael, Income Shifting from Transfer Pricing: Further Evidence from Tax Return Data, 94 Journal of Public Economics 555 (2010).
Earlier version available at SSRN: https://ssrn.com/abstract=6022454.

The Pillar Two Regime in the Post-Implementation Era: Structural Mechanics and Geopolitical Fragmentation (2026)

  • By Pramod Kumar Siva
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This article analyzes the OECD Pillar Two global minimum tax following its initial implementation phase, focusing on the structural mechanics of the regime and emerging signs of geopolitical fragmentation. The author examines how divergent domestic implementation choices, enforcement asymmetries, and coordination challenges affect the operation of the income inclusion rule and undertaxed profits rule. The article highlights risks to coherence and convergence as jurisdictions adapt Pillar Two to local political and fiscal priorities.

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