Hardback
International Tax at the Crossroads
Institutional and Policy Reform in the Era of Digitalisation
9781800889019 Edward Elgar Publishing
In light of the significant transformations affecting international tax in recent years, this book offers in-depth examinations on a series of key issues on the taxation of cross-border transactions. Craig Elliffe brings together a wealth of acclaimed legal academics to consider how the Inclusive Framework (IF) is responding to the ways in which highly digitalised businesses operate.
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Contributors
Contents
More Information
In light of the significant transformations affecting international tax in recent years, this book provides an in-depth assessment of the key issues impacting the taxation of cross-border transactions.
Craig Elliffe brings together a wealth of acclaimed legal academics to consider how the Inclusive Framework (IF) is responding to the ways in which highly digitalised businesses operate. International Tax at the Crossroads examines the overarching aspects of international tax reform, evaluates the IF’s proposed multilateral tax reforms and outlines the alternative unilateral options available and their subsequent legal consequences. Chapters analyse whether proposed tax reforms are stable, who should be involved in formulating international tax policy, who is influencing international tax policy, and the options and issues which arise in the event that multilateral compromise does not work.
This insightful book will prove an essential read for students, academics and researchers interested in domestic and international tax law, commercial law and fiscal policy. It will also be of benefit to advisors, administrators, practitioners and officials working in the financial sector.
Craig Elliffe brings together a wealth of acclaimed legal academics to consider how the Inclusive Framework (IF) is responding to the ways in which highly digitalised businesses operate. International Tax at the Crossroads examines the overarching aspects of international tax reform, evaluates the IF’s proposed multilateral tax reforms and outlines the alternative unilateral options available and their subsequent legal consequences. Chapters analyse whether proposed tax reforms are stable, who should be involved in formulating international tax policy, who is influencing international tax policy, and the options and issues which arise in the event that multilateral compromise does not work.
This insightful book will prove an essential read for students, academics and researchers interested in domestic and international tax law, commercial law and fiscal policy. It will also be of benefit to advisors, administrators, practitioners and officials working in the financial sector.
Contributors
Contributors: Matt Andrew, Reuven Avi-Yonah, Philip Baker, Richard Collier, Wei Cui, Michael Devereux, Craig Elliffe, Michael Littlewood, Ruth Mason, Chris Noonan, Alison Pavlovich, Victoria Plekhanova, Wolfgang Schön, Miranda Stewart, John Vella
Contents
Contents:
Preface ix
Introduction: standing at the crossroads 1
Craig Elliffe and Matt Andrew
1 Robustness and resilience in international tax reform 21
Wolfgang Schön
2 The reform of the institutional structure of international taxation 49
Philip Baker KC
3 Unilateralism and multilateralism in international tax 71
Reuven Avi-Yonah
4 Stability of the international tax system in a changing world 95
Victoria Plekhanova and Chris Noonan
5 Tax states, jurisdiction and the multilateral reality 115
Miranda Stewart
6 The impact of the global minimum tax on tax competition 142
Michael Devereux and John Vella
7 Is the shift to taxation at the point of destination inexorable? 167
Matt Andrew and Richard Collier
8 Multilateral tax reform 194
Michael Littlewood
9 Arbitration of tax disputes after the BEPS Two Pillar Solution 222
Chris Noonan and Victoria Plekhanova
10 The Canadian Digital Services Tax 246
Wei Cui
11 Legal problems with digital taxes in the United States and Europe 266
Ruth Mason
12 Data as a tax base 288
Alison Pavlovich
Preface ix
Introduction: standing at the crossroads 1
Craig Elliffe and Matt Andrew
1 Robustness and resilience in international tax reform 21
Wolfgang Schön
2 The reform of the institutional structure of international taxation 49
Philip Baker KC
3 Unilateralism and multilateralism in international tax 71
Reuven Avi-Yonah
4 Stability of the international tax system in a changing world 95
Victoria Plekhanova and Chris Noonan
5 Tax states, jurisdiction and the multilateral reality 115
Miranda Stewart
6 The impact of the global minimum tax on tax competition 142
Michael Devereux and John Vella
7 Is the shift to taxation at the point of destination inexorable? 167
Matt Andrew and Richard Collier
8 Multilateral tax reform 194
Michael Littlewood
9 Arbitration of tax disputes after the BEPS Two Pillar Solution 222
Chris Noonan and Victoria Plekhanova
10 The Canadian Digital Services Tax 246
Wei Cui
11 Legal problems with digital taxes in the United States and Europe 266
Ruth Mason
12 Data as a tax base 288
Alison Pavlovich
