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The Tax Policy Outlook for Developing Countries: Reflections on International Formulary Apportionment

A retrospective analysis is offered by the author regarding his recently-completed extensive research on the technical feasibility of international formulary apportionment of corporate taxable income, as a replacement for the body of ‘arm’s-length...

From the Lab to the Field: a Review of Tax Experiments

In recent years, tax experiments have been gaining momentum and with new developments in methods and data availability, tax experiments have gradually moved away from lab settings and towards the field. This movement from the lab to the field has ...

A Review of Uganda’s Tax Treaties and Recommendations for Action

A Comparative analysis of treaties signed by Uganda and other neighbouring countries, is used in this paper and this is combined with interviews conducted with government officials and private sector tax advisers, to assess whether Uganda’s netwo...

Tax Base Erosion and Profit Shifting in Africa - Part 1 - Africa’s Response to the OECD BEPS Action Plan

Africa’s response to the OECD’s base erosion and profit shifting (BEPS) project is examined in this paper. The paper also acknowledges that BEPS concerns for developing countries (such as those in Africa) may not necessarily be the same as those ...

Taxing Multinational Enterprises as Unitary Firms

The issues raised in this paper explores the international tax rules of explicitly treating multinational enterprises (MNEs) as single or unitary firms. Firstly, it briefly explains why reform of international corporate taxation is important part...

International Tax Disputes: Between Supranational Administration and Adjudication

This paper contributes to the important debate on how to improve the resolution of international tax disputes. It starts by outlining the context and development of international tax dispute resolution, then it analyzes its nature in a comparative...

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