Tax Sovereignty and International Tax Reform

Document Type


Publication Date


Source Publication

Canadian Tax Journal. Volume 52, Number 1 (2004), 141-148.


administration; international taxation; sovereignty; Tax Policy; transfer pricing; withholding taxes


The book is a study of the current state of international tax law and its application (or non-application) to electronic commerce in Canada, China, Hong Kong, Japan, Singapore, and the United States. Its purpose is to examine the extent to which current theories and principles of international taxation remain valid and the extent to which the fundamental issues need to be rethought in the age of electronic commerce. Chapter 12 argues that the existing concepts and principles have served the world well in the “old” economy, but decreasingly serve to carve up the international tax base in a reasonable and sustainable way in the “new” economy. I discuss why the concepts of corporate residence, characterization of income, source, and permanent establishment are increasingly difficult to apply. I also analyze why transfer-pricing rules are problematic in terms of economic theory, administrative efficiency, and the interpretation of article 9 of the model tax convention prepared by the Organisation for Economic Co-operation and Development (OECD).

Creative Commons License

Creative Commons License
This work is licensed under a Creative Commons Attribution-Noncommercial-No Derivative Works 4.0 License.

This document is currently not available here.