In this essay, we review criticisms of both the concept of international tax arbitrage and regulatory responses meant to reduce such arbitrage. We conclude that although objections to curbing arbitrage have merit, they are not so fundamental that they should stand in the way of reforms. Finally, we explore recent international cooperative efforts — pursued under the auspices of the OECD/G20 BEPS Project — to curb international tax arbitrage. This article is a reprint of a chapter from the festschrift for David Rosenbloom entitled Thinker, Teacher, Traveler: Reimagining International Taxation. The festschrift was published by the IBFD and is available on their website.

Ruth Mason & Pascal Saint-Amans, Has Cross-Border Arbitrage Met Its Match?, 41 Virginia Tax Review (2021).