Who should tax multinationals? National political figures sometimes signal their assumptions by making superior or even exclusive claims about who may tax “their” multinational companies, and it is common to hear such companies or their incomes referred to as “belonging” to one nation or another. The rhetoric reflects conventional wisdom about sovereign nations and their assumed entitlements, and is often invoked to curb or even sanction the seemingly excessive tax jurisdictions of some nations. But this conventional wisdom often ignores the fundamental dependence of multinationals on ongoing, extensive, and multifaceted regulatory cooperation involving most of the nations of the world. The goal of this essay is to demonstrate that given this dependence, there are no clear legal or normative boundaries to virtually any asserted tax jurisdiction. The claim provides a solution for neither double taxation nor the problems associated with excessive tax competition, but the essay concludes that recognizing the dependence of governments and “their” multinationals on multilateral cooperation should lead to an increase in focus on how nations go about negotiating the terms of their cooperation on tax.

中文翻译：

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谁应该向跨国公司征税？

谁应该对跨国公司征税？国家政治人物有时会通过对谁可以向“他们的”跨国公司征税提出优越甚至排他性的主张来表明他们的假设，并且经常听到这些公司或其收入被称为“属于”一个国家或另一个国家。这些言论反映了关于主权国家及其假定权利的传统观念，并且经常被用来遏制甚至制裁某些国家看似过度的税收管辖权。但这种传统智慧往往忽视了跨国公司对涉及世界大多数国家的持续、广泛和多方面监管合作的根本依赖。本文的目的是证明，鉴于这种依赖性，几乎任何声称的税收管辖权都没有明确的法律或规范界限。