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There are two largely distinct bodies of literature and corresponding research areas in international taxation. On the one hand, there is the big and continuously growing body of theoretical and empirical literature on tax competition, mainly in the field of economics; on the other, there is a large body of mostly legal literature dealing with inte...

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... Positive values are found in cases when loss carry-forwards are available to the affiliate. Bernard et al. (2008) Outcome(s): The paper shows that the wedge between the arm's-length export price and the intra-firm export price of US-based multinationals is negatively related to the taxation of corporate income in the foreign import country; this response indicates that tax-motivated transfer pricing is present in intra-firm export prices of US-based multinational companies Years and countries included: 1993-2000; the United States and 140 partner countries Specification and estimator applied: Log-level specification; pooled OLS with product fixed effects Dependent variable: The dependent variable is the wedge between the arm's- length export price and the intra-firm export price of US-based multination- als; data from the Linked/Longitudinal Firm Trade Transaction Database (LFTTD), which is based on data from the US Census Bureau and the US Customs Bureau, are used Tax variable of main interest: Statutory tax rate on corporate income and average tax rate on corporate income in the host country of US-based multinationals' affiliates Control variables: Tariff rate, log(employment of the affiliate), firm export share, log(real exchange rate with the US dollar), 10g(GDP per capita) Semi-elasticities Table 14 Semi-elasticity mean Semi-elasticity min. Semi-elasticity max. ...

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The international regime or “transnational legal order” (TLO) (Shaffer & Halliday this volume) of taxation consists of a body of multilateral, bilateral, and unilateral hard and soft laws regulating the tax treatment of cross-border economic activities, especially investment activities. The chapter reconstructs the dynamics of change of this TLO since its creation in the 1920s. Taking a diachronic perspective, it shows how the initial success of the TLO in establishing a settled normative order for avoiding the international double taxation of cross-border economic activities unintentionally created the follow-up problem of international tax competition. This triggered a new cycle of transnational legal ordering that challenged the initial settlement. The result is a TLO covering more issues at lower levels of normative settlement and with lower issue alignment.