2024
Oxford Business Tax Blog
The Functional Fallacy
By Richard Collier (Oxford University Centre for Business Taxation) and Ian Dykes (PwC), 2 December 2025
The BEPS project made some far-reaching changes to the transfer pricing rules. One of the most significant of these changes was the introduction of a new “conduct-based” approach to how transactions involving related parties are to be construed for the purposes of those rules. This blog explores some of the difficulties that have emerged with this new focus on conduct in applying the income allocation rules.
Treading the UK gilt market tightrope
By Paul Brice (University of Oxford), 28 October 2025
When government debt is high, the impact of fiscal policy choices on gilt yields matters. This blog discusses the implications for tax policy. It argues that tax policies which facilitate economic growth and therefore improve the serviceability of government debt in the long term seem more likely to induce a positive yield response.
How much do fuel taxes really cut fuel use?
By Ander Iraizoz (Oxford University Centre for Business Taxation) and José M. Labeaga (UNED), 30 September 2025
Fuel taxes are one of the most widely used tools for tackling climate change, but their effectiveness in curbing CO₂ emissions hinges crucially on the price elasticity of fuel demand. This blog summarizes recent research estimating this elasticity in the context of regional fuel tax reforms in Spain. The analysis highlights that typical elasticity estimates may be severely biased due to cross-border fuel shopping and suggests that policy coordination is required for fuel taxes to achieve their intended environmental impact.
The Distribution of Profit shifting and the Global Minimum Tax
Sarah Clifford (University of Oxford), Jakob Miethe (LMU Munich), Camille Semelet (LMU Munich), 28 August 2025
By focusing exclusively on large multinational groups, the Global Minimum Tax aims to target most of the world’s profit shifting while keeping aggregate compliance costs at a reasonable level. This blog summarizes recent research studying whether the current size threshold strikes the right balance between these two conflicting objectives. Using administrative data from Germany, it shows that revenue effects vastly dominate compliance costs above the current threshold but not below, suggesting that a lower threshold would entail relatively high efficiency costs.
Is the Digital Services Tax a tariff?
Michael Devereux (Emeritus Director, Oxford University Centre for Business Taxation), 26 March 2025
Should the UK government be willing to abandon the Digital Services Tax (DST), possibly as a part of a possible agreement with the US to avoid escalation of tariffs? In principle, that should depend on the nature of the tax. Michael Devereux questions whether the DST is in effect a tariff itself. If so, it is hard to justify keeping it whilst arguing against US tariffs on UK goods and services.
The Don and The International Tax System
Richard Collier (Oxford University Centre for Business Taxation), 24 January 2025
The release by President Trump earlier this week of a short document on the OECD Global Tax Deal has been widely interpreted as signalling a conclusive end to the prospects for US adoption of the OECD’s Two Pillar solution that has been under consideration for some time. In this blog, the author comments on these developments and explores what they might lead to.
