active financing exception 44
active income 4, 6–7, 115–16
benefits principle see benefits principle
BEPS see Base Erosion and Profit Shifting
inbound taxation 24–9
outbound taxation 47–50
reconsidering the benefits principle 68–9, 72–3, 81–5
single tax principle see single tax principle
source rules 13, 14, 16
administrative practices 128
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