Date of Award


Degree Type


Degree Name

Doctor of Juridical Science (S.J.D.)

First Advisor

Reuven Avi-Yonah

Second Advisor

Laura Nyantung Beny

Third Advisor

Alan Schenk


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