Date of Award
2016
Degree Type
Dissertation
Degree Name
Doctor of Juridical Science (S.J.D.)
First Advisor
Reuven Avi-Yonah
Second Advisor
Laura Nyantung Beny
Third Advisor
Alan Schenk
Abstract
The purpose of this Dissertation is to analyze the current ills of the international tax system with a special focus on developing countries, and to structure and present a Unitary Taxation System (“UT”) as a solution to the legitimate and multifaceted complaints about current international taxation of multinational companies (“MNEs”). The research aims at presenting a UT that would restore credibility in the international tax arena by providing fiscal predictability and certainty to MNEs, and ensuring appropriate taxation by all countries (specifically developing nations) of all “real” economic activity within their borders. Although this issue has been previously explored, there is currently a vacuum to be filled concerning a coherent and complete UT as an alternative to the current taxation of MNEs from a developing countries’ perspective. Specifically, there is a need for a major research and elaboration of a specific UT that would satisfy the legitimate concerns of developing countries while not alienating the developed world and MNEs. That is the goal of this Dissertation
Citation
Pouga Tinhaga, Zachée, "From Avoiding ‘Double Taxation’ Yesterday to Avoiding ‘Double Non-Taxation’ Today: The Urgent Need for an International Tax Regime Based on Unitary Tax Principles" (2016). SJD Dissertations.
https://repository.law.umich.edu/sjd/6