Description
Book SynopsisIn 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.
Table of ContentsContents: 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
