Dispute prevention and dispute resolution in cross-border business taxation: International legal comparison, empirical impact analysis and determinants

• Applicant: Professor Dr. Jost Heckemeyer
• Subject Area: Accounting and Finance
• Term: since 2025
• Project identifier: Deutsche Forschungsgemeinschaft (DFG) - Project number 563619761

Legal uncertainty, tax complexity and double taxation risks in crossborder business activities have increased sharply in the course of the fight against international tax avoidance in recent years. Procedures for the prevention and resolution of international tax disputes therefore play a potentially very important role. The Inclusive Framework on Base Erosion and Profit Shifting (BEPS) has agreed on minimum standards for dealing with impending or actual tax conflicts. The EU has set standards with the introduction of the EU Dispute Settlement Directive. Nevertheless, there is currently considerable heterogeneity in the quality of international procedural mechanisms for dealing with taxation conflicts. This raises the question of what the implications are. Surprisingly, there is hardly any direct evidence on the impact and relevance of these procedures in a cross-border context. The proposed research project endeavours to eliminate (or at least reduce) the existing deficits in the understanding of the nature and role of international procedures for the avoidance or resolution of bilateral or multilateral taxation conflicts. Accordingly, the aim of the proposed research project is to document in detail the status quo of established procedures for dispute prevention and dispute resolution in tax matters, to present it in international comparative terms and then to analyse the effect on corporate investment decisions and intra-group tax avoidance using quantitative-empirical estimation methods. The determining factors of the legal and practical quality of intergovernmental mechanisms for dispute prevention and resolution will also be investigated.

• DFG Programme: Research Grants