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Oxford University Centre for Business Taxation

Oxford University Centre for Business Taxation

International Business Tax Group

In 2013 the CBT Director, Professor Michael Devereux, invited an international group of economists and lawyers to meet to reconsider the fundamentals of the international tax system, and to propose more considered reforms. The group first met in December 2013, and has been working and meeting together since then.

The group has two main goals:

  • To set out and examine fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries.
  • To evaluate the existing system and potential reform options.

The group has considered a number of reform options, including the BEPS reform package put forward by the OECD, strengthening world wide taxation and unitary taxation and formulary apportionment. The group gave particular consideration to two radically different systems:

  • A residual profit allocation system.
  • A destination-based cash flow Tax

A common feature of these two approaches is that they assign taxing rights partly or fully to the location of relatively immobile factors: shareholders or consumers.

The group aims to publish a book summarising its research and findings.

Group members

Michael Devereux, Professor of Business Taxation, Saïd Business School

Michael Devereux is Director of the Oxford University Centre for Business Taxation and Professorial Fellow at Oriel College, Oxford. He is Research Director of the European Tax Policy Forum, and Research Fellow of the Centre for Economic Policy Research and CESifo. He is assistant editor of the British Tax Review and is a member of the Editorial Board of the World Tax Journal. He is a member of the Business Forum on Tax and Competitiveness, chaired by the Exchequer Secretary.

Alan Auerbach, Robert D Burch Professor of Economics and Law, University of California - Berkeley

Alan J Auerbach is the Robert D Burch Professor of Economics and Law, Director of the Burch Center for Tax Policy and Public Finance, and former Chair of the Economics Department at the University of California, Berkeley. He is also a Research Associate of the National Bureau of Economic Research and previously taught at Harvard and the University of Pennsylvania, where he also served as Economics Department Chair. He was Deputy Chief of Staff of the US Joint Committee on Taxation in 1992 and has been a consultant to several government agencies and institutions in the United States and abroad.

Michael Keen, Deputy Director of Fiscal Affairs, International Monetary Fund

Michael is Deputy Director of the Fiscal Affairs Department of the International Monetary Fund, where he was previously head of the Tax Policy and Tax Coordination divisions. Before joining the Fund, he was Professor of Economics at the University of Essex and visiting Professor at Kyoto University. He is Honorary President of the International Institute of Public Finance (of which he was elected President from 2003 to 2006), and in 2008 was ranked the world’s leading author in public economics journals.

Paul Oosterhuis, Of Counsel, Skadden LLP

Paul Oosterhuis is a practitioner in the Washington, DC office of Skadden, Arps, Slate, Meagher & Flom. Paul has had extensive experience in international acquisition and disposition transactions, financing arrangements and tax planning for US and foreign-based multinational corporations. He frequently represents clients on controversy matters, as well as regulations and rulings proceedings, with the Internal Revenue Service. In addition, he represents clients in intercompany pricing matters, including docketed Tax Court cases and Advance Pricing Agreement negotiations.

Wolfgang Schön, Managing Director, Max Planck Institute for Tax Law and Public Finance

Wolfgang Schön is the Managing Director of the Max Planck Institute for Tax Law and Public Finance in Munich, Honorary Professor at Munich University and an International Research Fellow with the OUCBT. He is Vice Chair of the Permanent Scientific Committee of IFA, Board Member of the European Association of Tax Law Professors and Member of the Board of Trustees of the International Bureau of Fiscal Documentation in Amsterdam.

John Vella, Associate Professor at the Oxford University Centre for Business Taxation

John Vella is an Associate Professor at the Oxford University Centre for Business Taxation and a Supernumerary Fellow of Harris Manchester College. John studied law at the University of Malta (BA and LLD) and the University of Cambridge (LLM and PhD). He was previously Norton Rose Career Development Fellow in Company Law at Oxford. John is a former Convenor of the Tax Section of the UK Society of Legal Scholars and is currently a Deputy Director of the new MSc in Taxation at Oxford.


The Centre has been supported in the work of the International Business Tax Group by the following centres:

Max Planck Institute for Tax Law and Public Finance

and Burch Center for Tax Policy and Public Finance

We are also grateful for financial support  from the Nuffield Foundation


Alan Auerbach, Michael P. Devereux, MIchael Keen and John Vella "Destination-based Cash Flow Taxation": Centre for Business Taxation Working Paper - 17/01. Available at SSRN:

Wolfgang Schön : Destination-Based Income Taxation and WTO Law: A Note. In:  Jochum , H./Essers , P./  Lang , M./Winkeljohann , N./Wiman , B.  (Ed.) : Practical Problems in European and International Tax Law - Essays in honour of Manfred Mössner. Amsterdam, IBFD, 2016 , S. 429  - 451 = Schoen, Wolfgang, Destination-Based Income Taxation and WTO Law: A Note (January 2016). Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2016-3. Available at SSRN: or