2010
DOI: 10.3138/9781442660021
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Globalization and Its Tax Discontents

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Cited by 8 publications
(5 citation statements)
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“…The diverging interests between these two groups of countries made it much harder to reach an agreement on how to reform corporate taxation. Since the dominant OECD tax model treaties are generally regarded as more favourable towards residence countries (Cockfield, 2010), it is evident that the net source countries of the G20 tried to correct this imbalance through the BEPS process (Herzfield, 2016).…”
Section: Us Preferences and Redistributive Conflicts In Bepsmentioning
confidence: 99%
“…The diverging interests between these two groups of countries made it much harder to reach an agreement on how to reform corporate taxation. Since the dominant OECD tax model treaties are generally regarded as more favourable towards residence countries (Cockfield, 2010), it is evident that the net source countries of the G20 tried to correct this imbalance through the BEPS process (Herzfield, 2016).…”
Section: Us Preferences and Redistributive Conflicts In Bepsmentioning
confidence: 99%
“…318 Whereas states initially departed more liberally from the OECD Model, they now mirror it more closely as the OECD serves as focal point for the normative evolution of tax treaties and contributes to the normative convergence of tax treaties. 319 This convergence, in turn, facilitated the work of the MLI since differences between DTTs were not as pronounced as one would suspect in a network of bilateral treaties without formal centralization. The MLI could harness this relative homogeneity and leverage the work that had gone into updating the OECD Model and its commentary to codify targeted adjustments in the MLI.…”
Section: B Normative Convergence In Tax But Not Investmentmentioning
confidence: 95%
“…A fifth issue is that in cases concerning DRM revenue from international taxpayers, especially corporations, there is a fundamental conflict of interest between developing countries and OECD donors which also want favorable conditions for their resident multinational companies. There is a myriad of literature on how the international tax regime is lopsided in favor of net residence countries (Cockfield 2010;International Monetary Fund 2019;Picciotto 2013), but the global tax regime is not in the scope of the MTRS. 5 What should be in its scope however are the tax treaties that developing countries conclude, especially now when many of them are part of the BEPS IF whose minimum standards will be disseminated through the network of bilateral tax treaties.…”
Section: Issue 5: Potential Conflict Of Interest Between Donor and Pa...mentioning
confidence: 99%