Rocha, Sergio André, Christians, Allison 　著

目次

Editors Contributors Preface Part I The Essential Paradox of Tax Sovereignty 1 BEPS and the Power to Tax 2 Tax Sovereignty and Digital Economy in Post-BEPS Times 3 Justification and Implementation of the International Allocation of Taxing Rights: Can We Take One Thing at a Time? 4 An Essay on BEPS, Sovereignty, and Taxation Part II Challenge to the Foundational Principles of Source and Residence 5 Evaluating BEPS 6 Jurisdictional Excesses in BEPS’ Times: National Appropriation of an Enhanced Global Tax Basis 7 Taxing the Consumption of Digital Goods Part III Acceptance and Implementation of Consensus by Differently-Situated States 8 The Birth of a New International Tax Framework and the Role of Developing Countries 9 The Other Side of BEPS: “Imperial Taxation” and “International Tax Imperialism” 10 Country-by-Country Over-Reporting? National Sovereignty, International Tax Transparency, and the Inclusive Framework on BEPS 11 How Are We Doing with BEPS Recommendations in the EU? 12 U.S. Tax Sovereignty and the BEPS Project Index