The OECD's Approach to IP-Boxes as a Norm: Hard, Soft or Half-Baked?

British Tax Review 4 2017

16 Pages Posted: 6 Nov 2017

Date Written: 2017

Abstract

This article investigates the origin and specific mechanics of the sense of binding obligation inspired by the most recent developments in international taxation. Taking the case study of the “Modified Nexus Approach” to Intellectual Property (IP)-Boxes, the article identifies the notion of sociological validity as a parallel authority that compensates for the lack of legal validity of the OECD’s soft law instruments. The existence of sanctioning mechanisms is identified as a key factor for the emergence of such sociological validity.

Note: "This material was first published by Sweet & Maxwell Limited in Pedro Guilherme Lindenberg Schoueri, The OECD’s Approach to IP-Boxes as a Norm: Hard, Soft or Half-Baked?, Issue 4 2017 of the British Tax Review and is reproduced by agreement with the Publishers".

Suggested Citation

Lindenberg Schoueri, Pedro Guilherme, The OECD's Approach to IP-Boxes as a Norm: Hard, Soft or Half-Baked? (2017). British Tax Review 4 2017, Available at SSRN: https://ssrn.com/abstract=3062189
No contact information is available for Pedro Guilherme Lindenberg Schoueri

Do you have a job opening that you would like to promote on SSRN?

Paper statistics

Downloads
118
Abstract Views
642
Rank
442,594
PlumX Metrics