Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle A Critical Analysis of Structural Paradigms Underlying Corporate Income Taxation and Proposals for Reform - Series on International Taxation

Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle' intends to demonstrate that the profit shifting phenomenon (e.g., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested "presumptive benefit principle" so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States.