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4 Conceptual Problems

From: International Law of Taxation

Peter Hongler

From: Oxford Public International Law (http://opil.ouplaw.com). (c) Oxford University Press, 2022. All Rights Reserved.date: 18 August 2022

The last chapter of the book reviews whether the international tax regime has been a success or a failure and based on these remarks, it is assessed what the reasons are for potential success and potential failure. Afterwards, reference is made to three of the most pressing issues in the current international tax regime. This includes measures against aggressive tax planning, specific issues triggered by the taxation of the digital economy, and a discussion of whether it would better to switch from the arm’s length principle to a formulary system. The chapter will also cover some of the most recent proposals to change the current international tax regime as part of the Pillar 1 and Pillar 2 work of the Inclusive Framework.

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