Tax Law

International Tax Primer, currently in its fifth edition, follows the format and sequence of earlier editions, with updates on ongoing developments regarding the Organisation for Economic Co-operation and Development’s (OECD’s) base erosion and profit shifting project, the revisions to the OECD Guidelines on Transfer Pricing, and updates to the OECD and UN Model Conventions. The Primer furnishes the reader with an introductory analysis of the major issues that a country must confront in designing its international tax rules and coordinating those rules with the tax systems of its trading partners, with numerous examples drawn from the practices of both developed and developing countries. Indubitably, the most crucial development in international tax since the fourth edition in 2018 has been the OECD Inclusive Framework’s Pillar One and Pillar Two proposals for dealing with the tax challenges posed by the digital economy. This edition analyzes in depth both Pillar One, which proposes new nexus and profit-allocation rules for the residual profits of the largest and most profitable digital multinationals, and Pillar Two, which proposes a global minimum tax on large multinationals. In addition, several sections, such as those dealing with digital services taxes, hybrid arrangements, and new Article 12B of the UN Model Convention dealing with automated digital services, as well as a brief history of international tax, among others, have been added to the fifth edition.

Offers a comprehensive outline of the international tax regime, engaging critically with relevant institutions such as the UN, the OECD, the Inclusive Framework, and the Global Forum
Provides a compelling overview of the international tax regime's interaction with other international law disciplines, including trade law, investment treaty law, and human rights law
Forms part of the Elements of International Law series; a highly reliable, objective, readable, and in-depth collection engaged in the discipline of international law

Bringing a unique voice to international taxation, this book argues against the conventional support of multilateral co-operation in favour of structured competition as a way to promote both justice and efficiency in international tax policy. Tsilly Dagan analyzes international taxation as a decentralized market, where governments have increasingly become strategic actors. While many of the challenges of the current international tax regime derive from this decentralized competitive structure, Dagan argues that curtailing competition through centralization is not necessarily the answer. Conversely, competition - if properly calibrated and notwithstanding its dubious reputation - is conducive, rather than detrimental, to both efficiency and global justice. International Tax Policy begins with the basic normative goals of income taxation, explaining how competition transforms them and analyzing the strategic game states play on the bilateral and multilateral level. It then considers the costs and benefits of co-operation and competition in terms of efficiency and justice.