Taxing Corporates: 2025 and Beyond

This book of conference proceedings of the IBFD Academic Tax Conference held in May 2025 on the theme "Taxing Corporates: 2025 and Beyond" explores critical issues with a forward-thinking perspective concerning innovative options for reforming corporate taxation.

Why this book?

This book contains the proceedings from the IBFD Academic Tax Conference (ATC), held at the IBFD in Amsterdam on 15-16 May 2025. The conference theme that frames these papers is presented in the title of this book, namely “Taxing Corporates: 2025 and Beyond”.

Over the last few decades, much of the focus of the international tax community has been on corporate income tax, particularly focused on large multinational corporations. However, the outcomes of the BEPS Action Plan (including the MLI) and the OECD Two-Pillar solution do not appear to address all criticisms and needs of the international tax community as regards corporate taxation. Moreover, the concrete measures adopted in the implementation of such projects have been the subject of significant criticism. The increasing complexity of the corporate income tax system and its relationship with other taxes is, at present, quite concerning.

The book consists of six parts that thematically group the chapters. Part I investigates the role of tax residence in the framework of international taxation. Two contributions look at this topic from different but complementary angles. Part II examines the interactions of various legal frameworks and investigates the potential impacts these interactions may have on corporate taxation. Part III addresses one of the most pressing and challenging topics in international corporate taxation: Transfer Pricing Issues. Part IV examines selected aspects of the tax frameworks of two distinct yet similarly integrated political entities: the European Union (EU) and the United States (US). Part V is a bold exploration of unconventional ideas that may challenge readers and evoke discomfort. Part VI concludes the book with an equally thorough assessment of source taxation, thus completing a perfect circle.

Despite several decades of implementation, corporate taxation continues to raise numerous questions. These questions underpin the contributions presented at the conference and point to the purpose and rationale behind the existence of corporations and the independent corporate income taxation system.

This book aims to contribute to the corporate taxation debate and help inform its future directions.