This article analyses the international tax principles in double tax treaties regarding the allocation of taxing rights between residence states and source states. The article explains that from the early twentieth century ...

Increased opportunities for aggressive tax planning (ATP) schemes by multinationals has heightened pressure on governments and policy-makers to curtail these activities. However, the design of most anti-avoidance rules ...

This article assesses the OECD Pillar Two Model Rules from a developing country perspective. The article will assist developing countries in deciding whether the Model Rules are suitable for their economies, and whether ...

The COVID-19 global pandemic has posed an economic crisis that might derail the ability of many countries to achieve the UN sustainable development goals by the 2030 deadline. Although countries have come up with economic ...