Transformation of the International Tax System is a 5 year research project that takes place between September 2017 and August 2022. The project is funded by the Academy of Finland and the University of Tampere. The project is managed by the research group of business law and tax law at the Faculty of Management of the University of Tampere.


The interconnected and universal processes of digitalization and automatization set an unprecedented challenge for the functioning of the international tax system whose basic structure dates back all the way to the early 1900s. From the perspective of international taxation the two main features of the digital age are:

  1. Economic activity no longer requires physical presence.
  2. The importance of intangibles (trademarks, patents, copyrights, knowhow) has significantly increased in the global value chain due to the expanded scope of digital services and because the manufacturing of tangible goods has become a less costly and more routine operation.

These developments erode the fundamental concepts of international tax law that determine which state has the jurisdiction to tax cross-border income. Ultimately the tax base eroding processes have resulted in the wide-ranging phenomenon of international double non-taxation of multinational enterprises. This is a pressing global concern in terms of financing the welfare state as well as ensuring the competition neutrality between local and global economic operators and, thus, economic efficiency.

The objective of the project is to better understand the fundamental change faced by the international tax system and how to manage that change. The project deals e.g. with the following tax-specific themes:

  • taxation of the digital economy
  • transfer pricing
  • tax avoidance
  • tax transparency
  • supranational tax regulation and its implementation
  • taxation of financial instruments

The partner organizations of the project are IBFD Research and Information Center in Amsterdam, the Finnish Ministry of Finance and the Finnish Tax Administration. Scientific collaboration and support is provided by leading experts of international and European tax law: Prof. Pasquale Pistone (Academic Chairman of IBFD), Prof. Bertil Wiman (Uppsala University), Ass. Prof. Marcel Schaper (Maastricht University), Prof. Marjaana Helminen (University of Helsinki) and Prof. Reijo Knuutinen (University of Turku School of Economics).