Encapsulating the multitude of challenges faced by the international corporate tax regime, this timely Research Handbook provides an in-depth comparative legal analysis of corporate income tax as it is practiced across the world. Beginning with four foundational chapters exploring the purpose and history of corporate tax, the Handbook goes on to provide a synthesis of the key issues in corporate taxation within the US regime, addressing some of the cutting-edge normative issues in designing a corporate tax. It then proceeds to set this against the experience in the EU and eleven other countries including the UK, Canada, China, Japan, India, Brazil and New Zealand. A further section on corporate tax planning includes careful analysis of such issues as corporate tax shelters, economic substance, social responsibility and governance, before final, horizon-scanning chapters consider the future of corporate tax and whether a new form of corporate tax might be possible. With a variety of paths to reform proposed throughout, this Research Handbook will prove an invigorating read for tax scholars working on taxation and tax law as well as for tax practitioners and those in fiscal policy seeking ways to improve, or navigate, the current state of affairs in international corporate tax law.

In the last twenty years a critically important debate has dominated international tax scholarship: whether an international tax regime exists and if countries are constrained by it within their own tax legislation. This debate has had major implications on the current post-financial crisis efforts by governmental organizations, such as the G20 and OECD, in drafting multilateral international tax rules. This research review draws upon the most important papers published in the last two decades to comprehensively address the increasingly relevant issues of international tax law.

This book examines the coherent international tax regime that is embodied in both the tax treaty network and in domestic laws, and the way it forms a significant part of international law, both treaty based and customary. The practical implication is that countries are not free to adopt any international tax rules they please, but rather operate in the context of the regime, which changes in the same ways international law changes over time. Thus, unilateral action is possible, but is also restricted, and countries are generally reluctant to take unilateral actions that violate the basic norms that underlie the regime. The book explains the structure of the international tax regime and analyzes in detail how US tax law embodies the underlying norms of the regime.

This book examines the coherent international tax regime that is embodied in both the tax treaty network and in domestic laws, and the way it forms a significant part of international law, both treaty based and customary. The practical implication is that countries are not free to adopt any international tax rules they please, but rather operate in the context of the regime, which changes in the same ways international law changes over time. Thus, unilateral action is possible, but is also restricted, and countries are generally reluctant to take unilateral actions that violate the basic norms that underlie the regime. The book explains the structure of the international tax regime and analyzes in detail how US tax law embodies the underlying norms of the regime.