Edited by Craig Elliffe, Faculty of Law, University of Auckland, New Zealand

• Contents:Preface ixIntroduction: standing at the crossroads 1Craig Elliffe and Matt Andrew1 Robustness and resilience in international tax reform 21Wolfgang Schön2 The reform of the institutional structure of international taxation 49Philip Baker KC3 Unilateralism and multilateralism in international tax 71Reuven Avi-Yonah4 Stability of the international tax system in a changing world 95Victoria Plekhanova and Chris Noonan5 Tax states, jurisdiction and the multilateral reality 115Miranda Stewart6 The impact of the global minimum tax on tax competition 142Michael Devereux and John Vella7 Is the shift to taxation at the point of destination inexorable? 167Matt Andrew and Richard Collier8 Multilateral tax reform 194Michael Littlewood9 Arbitration of tax disputes after the BEPS Two Pillar Solution 222Chris Noonan and Victoria Plekhanova10 The Canadian Digital Services Tax 246Wei Cui11 Legal problems with digital taxes in the United States and Europe 266Ruth Mason12 Data as a tax base 288Alison Pavlovich

Edited by Craig Elliffe, Faculty of Law, University of Auckland, New Zealand

• Contents:Preface ixIntroduction: standing at the crossroads 1Craig Elliffe and Matt Andrew1 Robustness and resilience in international tax reform 21Wolfgang Schön2 The reform of the institutional structure of international taxation 49Philip Baker KC3 Unilateralism and multilateralism in international tax 71Reuven Avi-Yonah4 Stability of the international tax system in a changing world 95Victoria Plekhanova and Chris Noonan5 Tax states, jurisdiction and the multilateral reality 115Miranda Stewart6 The impact of the global minimum tax on tax competition 142Michael Devereux and John Vella7 Is the shift to taxation at the point of destination inexorable? 167Matt Andrew and Richard Collier8 Multilateral tax reform 194Michael Littlewood9 Arbitration of tax disputes after the BEPS Two Pillar Solution 222Chris Noonan and Victoria Plekhanova10 The Canadian Digital Services Tax 246Wei Cui11 Legal problems with digital taxes in the United States and Europe 266Ruth Mason12 Data as a tax base 288Alison Pavlovich