Collected Articles and Essays on Tax Law vol.4 Kokusai Kazei no Kenkyu (Studies on International Taxation)

Volume 4: Studies in International Taxation
— Tax Jurisdiction and Transfer Pricing
 
Volume 4 addresses the complexities of international taxation and transfer pricing, focusing on the allocation of and conflicts over taxing jurisdiction.
 
Part V: Tax Jurisdiction
Through an analysis of international tax litigation, controlled foreign corporation (CFC) regimes (anti–tax haven rules), and the BEPS (Base Erosion and Profit Shifting) project, this section examines the legitimate boundaries within which states may exercise their taxing power. It further considers the withdrawal of taxing jurisdiction and the necessity for institutional reform, highlighting the inherent limitations of international tax coordination.
 
The essays on local taxation analyze jurisdictional conflicts between national and local governments, among various local authorities, and between domestic and foreign jurisdictions. This part presents a perspective that treats local governments as autonomous taxing entities.
 
Part VI: Transfer Pricing
This section systematically organizes the transfer pricing regime, covering its historical evolution, methods for profit calculation, the application of economic theory, and procedural issues. By addressing critical topics such as intangibles, risk allocation, and mutual agreement procedures (MAP), this part examines the theoretical and institutional challenges of transfer pricing from multiple analytical dimensions.
 
The Significance of Volume 4
Volume 4 conceptualizes taxing power not merely in quantitative terms, but as a matter of jurisdiction. In doing so, it theorizes the spatial and institutional limits of tax law in a globalized economy.
 

(Written by NAKAZATO Minoru, Professor Emeritus, Graduate Schools for Law and Politics / 2026)