The Urgently Needed New International Framework: Unitary Taxation

The International tax regime is at a crossroads and the path to be chosen is yet to be determined. Solutions have been tested none of which has satisfied the needs of the various actors in the arena. The purpose of this book 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 the current system of taxing MNEs. Dr. Pouga exposes the growing realization by some that taxes are only paid by the naïve; and the profound global outcry that is menacing the integrity of tax systems. He develops a proposal to 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. Dr. Pouga eloquently argues that tax law and policy ought to move from the singlar need to avoid double taxation which prevailed yesterday, to the urgent need to avoid double non-taxation common today; and concludes that a well crafted UT would achieve that goal.