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Tax Treaty Obstacles in Implementing the Pillar Two Global Minimum Tax Rules and a Possible Solution for Eliminating the Various Challenges
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Tax Treaty Obstacles in Implementing the Pillar Two Global Minimum Tax Rules and a Possible Solution for Eliminating the Various Challenges (2022)Tax Treaty Obstacles in Implementing the …The Evolution of Controlled Foreign Corporation Rules and Beyond (2019)The Evolution of Controlled F…International Effective Minimum Taxation – The GLOBE Proposal (2019)International Effective Minim…Transfer Pricing and the Arm's Length Principle After BEPS (2017)Transfer Pricing and the Arm'…Arm’s Length: Beyond the Guidelines of the OECD (2015)Arm’s Length: Beyond the Guid…The transactional ghost of Article 9(1) of the OECD Model (2009)The transactional ghost of Ar…The Nature of the Firm (1937)Corporations, Society, and the State: A Defense of the Corporate Tax (2004)Interpretative and Policy Challenges Following the OECD Multilateral Instrument (2016) from a Brazilian Perspective (2017)The True Nature of Tax Treaties (2019)INTERNATIONAL TAX PLANNING UNDER THE DESTINATION-BASED CASH FLOW TAX (2017)Residual Profit Allocation by Income (2019)Transfer pricing: changing views in changing times (2021)Is There Finally an International Tax System? (2021)GloBE and EU Law: Assessing the Compatibility of the OECD’s Pillar II Initiative on a Minimum Effective Tax Rate with EU Law and Implementing It within the Internal Market (2020)Some Considerations on the Limitation of Substance-Based Carve-Out in the Income Inclusion Rule of Pillar Two (2021)Earnings Stripping and Thin Cap Rules: Maintaining an Arm’s Length Distance (2013)Multinational Firm Theory and International Tax Law: Seeking Coherence (2016)Post-BEPS Application of the Arm’s Length Principle to Intangibles Structures (2016)
this work references cited by second hop

References

  • 2017Transfer Pricing and the Arm's Length Principle After BEPS76 cited
  • 2015Arm’s Length: Beyond the Guidelines of the OECD60 cited
  • 2019International Effective Minimum Taxation – The GLOBE Proposal49 cited
  • 2019The Evolution of Controlled Foreign Corporation Rules and Beyond40 cited
  • 2009The transactional ghost of Article 9(1) of the OECD Model40 cited

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