Double tax discrimination to attract FDI and fight profit shifting: The role of CFC rules

While the application of CFC rules to passive income of foreign companies established in classical tax havens generally would be regarded as justified, this is not the case

Participation in WTO negotiations, the implementation of WTO rules (for instance, rules on veterinary standards) and the reduction of MFN tariff rates have some of

As thin-capitalisation rules can be changed over time or vary from country to country, this also implies that some rules are harder to circumvent than others. This implies that the

Many countries focus on internal debt only, some countries restrict the total debt-to-asset ratio.⁷ In 2008, the average safe-harbor ratio of internal debt to equity was 3.4:1 in

We show that while permissive thin capitalization limits may be needed in developing countries to attract FDI, the amount of debt financing allowed by the permissive

The legality requirement to be discussed here is designed to avoid modifying the meaning of concepts which are not objects of the definition, thus implicitly

Axiom groups are used to identify which axioms are useful as rewrite rules, and to distinguish between different types of rules – e.g., simplification rules, reordering rules

This paper analyzes the Syrian involvement in Lebanon following the end of the Lebanese civil war in 1989/90 and until the death of Syrian President Hafiz al-Asad, which marked the