Global investment patterns mean that effective taxation of foreign investors is of increasing importance to the economies of lower income countries. It is thus

This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mi

Is the current U.S. tax system for taxing U.S. international business the appropriate one for the modern era of globalized business operations, or should its ba

In 2009, the United Kingdom changed from a worldwide to a territorial tax system, abolishing dividend taxes on foreign repatriation from many low-tax countries.

In 2009, the United Kingdom abolished the taxation of profits earned abroad and introduced a territorial tax system. Under the territorial system, firms have st