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

Abstract

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

Suggested Citation

Ault, Hugh J., Some Reflections on the OECD and the Sources of International Tax Principles (July 1, 2013). 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. Available at SSRN: https://ssrn.com/abstract=2287834 or http://dx.doi.org/10.2139/ssrn.2287834

Hugh J. Ault (Contact Author)

Boston College Law School ( email )

885 Centre Street
Newton, MA 02459-1163
United States

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