Open Access. Powered by Scholars. Published by Universities.®
Articles 1 - 2 of 2
Full-Text Articles in Law
The Rise And Fall Of Arm's Length: A Study In The Evolution Of U.S. International Taxation, Reuven S. Avi-Yonah
The Rise And Fall Of Arm's Length: A Study In The Evolution Of U.S. International Taxation, Reuven S. Avi-Yonah
Law & Economics Working Papers Archive: 2003-2009
A revised and updated version of the 1995 article (Va. Tax Review) on the evolution of US transfer pricing rules.
Tax Competition, Tax Arbitrage, And The Internation Tax Regime, Reuven S. Avi-Yonah
Tax Competition, Tax Arbitrage, And The Internation Tax Regime, Reuven S. Avi-Yonah
Law & Economics Working Papers Archive: 2003-2009
This paper argues that a coherent international tax regime exists, embodied in both 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 norms that underlie the regime. Those …