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Tax Competition, Tax Arbitrage And The International Tax Regime, Reuven S. Avi-Yonah
Tax Competition, Tax Arbitrage And The International Tax Regime, Reuven S. Avi-Yonah
Articles
In the past ten years, I have argued repeatedly that a coherent international tax regime exists, embodied both in the tax treaty network and in domestic laws, and that it forms a significant part of international law (both treaty-based and customary). The practical implication is that countries are not free to adopt any international tax rules they please, but rather operate in the context of the regime, which changes in the same ways international law changes over time. Thus, unilateral action is possible, but is also restricted, and countries are generally reluctant to take unilateral actions that violate the basic …
Bridging The North/South Divide: International Redistribution And Tax Competition, Reuven S. Avi-Yonah
Bridging The North/South Divide: International Redistribution And Tax Competition, Reuven S. Avi-Yonah
Articles
The most important social problem facing humanity at the beginning of the 21st century is the yawning divide in standards of living between the rich nations of the global North and the poor nations of the global South. The following table gives some indicia of the current gap in living standards. It shows that the majority of the population in most developing countries lives on less than two dollars a day; that in some developing countries, over a quarter of children aged 10-14 are employed in the work force; that mortality for children under five in developing countries can be …
Tax, Trade And Harmful Tax Competition: Reflections On The Fsc Controversy, Reuven S. Avi-Yonah
Tax, Trade And Harmful Tax Competition: Reflections On The Fsc Controversy, Reuven S. Avi-Yonah
Articles
This article contrasts three approaches to dealing with the BEPS problem: adopting a unitary taxation regime, ending deferral, and adopting anti-base-erosion measures. It concludes that while the first approach is the best long-term option, the other two are more promising as immediate candidates for adoption in the context of U.S. tax reform and the OECD BEPS project.