Kim & Avi-Yonah: The International Tax Revolution

Young Ran (Christine) Kim (Cardozo; Google Scholar) & Reuven S. Avi-Yonah (Michigan; Google Scholar), Introduction, in The International Tax Revolution (Cambridge University Press, forthcoming 2025):

The past decade has witnessed the creation of a new international tax regime (ITR). Since the advent of globalization in the 1980s and digitalization in the 1990s, the original ITR ceased to function as intended. The main problems were the increased mobility of capital related to intangibles, a relaxation of capital controls, and increased tax competition. The outcome was a significant fall in tax revenues that threatened the social safety net of the modern welfare state. The financial crisis of 2008 and harsh austerity measures led the public to pay attention to rich individuals and large corporations paying little tax on cross-border income. A new ITR has been created to resolve those problems. 

In particular, the United States enacted the Foreign Account Tax Compliance Act, which contributed for the OECD to develop a Common Reporting Standard for the automatic exchange of information; the OECD launched the Base Erosion and Profit Shifting project 1.0; and the EU enacted the Anti-Tax Avoidance Directives. These developments still have some limits, resulting in the advent of BEPS 2.0 consisting of two Pillars. The key question is how the new ITR will deal with inter-nation equity.

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