Some Reflections on the OECD and the Sources of International Tax Principles
Reprinted from Tax Notes International, Volume 70, Number 12, June 17, 2013, p. 1195
Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2013-03
10 Pages Posted: 3 Jul 2013 Last revised: 2 Apr 2014
Date Written: July 1, 2013
The article of Hugh J. Ault is the revised text of a lecture held on May 2, 2013, at the Max Planck Institute for Tax Law and Public Finance. It focuses on the OECD's work on the definition of Permanent Establishment, the transfer pricing treatment of Intangibles and the recently announced project on base erosion and profit shifting ("BEPS"). After describing these positive law developments, Ault relates to more basic questions of how principles of international tax law, and particular the normative claims to taxing rights, are estabilshed.
Keywords: International tax principles
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