Taxing Multinationals Preventing tax base erosion through the reform of cross-border intercompany deductions, ATTA Doctoral Series, vol. 7

One of the most significant trends in the evolution of global tax systems has been the rise from relative obscurity of thin capitalisation rules, which are perceived as anti-avoidance rules. Despite their prevalence, it is unclear whether thin capitalisation rules: (1) attain tax neutrality (specifically, do these rules mitigate the tax-induced cross-border debt bias); and, (2) are effective in both theory and practice. Taxing Multinationals approaches the issue of thin capitalisation from a novel perspective by conceptualising the cross-border debt bias as the 'disease' and thin capitalisation as merely the 'symptom'. The overarching question guiding this book is whether, given the opportunity to start over, the tax-induced cross-border debt bias would be better addressed by retaining thin capitalisation rules in their current form or whether an alternative reform would be more suited to dealing with this 'disease'. Taxing Multinationals: Preventing tax base erosion through the reform of cross-border intercompany deduction is the seventh volume in the Australasian Tax Teachers' Association (ATTA) Doctoral Series.

1 - Introduction
2 - Reviewing the Theoretical and Applied Literatures
3 - Designing a Principles-Based Evaluation Framework
4 - Evaluating Current Legal Practice on Cross-Border Intercompany Deductions
5 - Simulating Tax-Minimising Behavioural Responses to Current and Proposed Tax Rule
6 - Developing Principles-Based Proposals for Tax Reform
7 - Results and Conclusion

Ann Kayis-Kumar is a Lecturer in the School of Taxation and Business Law at UNSW.