This document summarizes the key arguments made in a paper endorsing non-G20 participation in the OECD's Base Erosion and Profit Shifting (BEPS) project. It argues that corporate income tax is even more important for developing country public finances than developed countries. However, the BEPS process currently excludes non-G20 countries. It recommends ensuring non-G20 countries can fully participate in rewriting international tax rules through the BEPS process. The success of BEPS should be judged on reducing double non-taxation while safeguarding developing country tax bases, not just aligning taxes with substance in G20 economies. Solutions must apply to all countries and support less resourced tax administrations
The way to Tax Multinational Corporations?Howie Thomas
John Woodward is an Australian Accountant who has invented a simplified way of Taxing Multinational Corporations globally. It's simplicity is such that you stop and think why has nobody done this before?
The way to Tax Multinational Corporations?Howie Thomas
John Woodward is an Australian Accountant who has invented a simplified way of Taxing Multinational Corporations globally. It's simplicity is such that you stop and think why has nobody done this before?
Learning Objectives
To review types of economic integration among countries
To examine the costs and benefits of integrative arrangements
To understand the structure of the European Union and its implications for firms within and outside Europe
To explore the emergence of other integration agreements, especially in the Americas and Asia
To suggest corporate response to advancing economic integration
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In recent years, many countries have actively sought to establish new bilateral and regional trade agreements (RTAs) to increase trade and spur economic growth. The current proliferation of RTAs reflects, in part, a demand for deeper integration than what has been achieved by older multilateral agreements. To the extent that they go beyond commitments made in the WTO and remain open to additional participation by countries committed to meeting their standards, RTAs can indeed complement the multilateral trading system.
Learning Objectives
To review types of economic integration among countries
To examine the costs and benefits of integrative arrangements
To understand the structure of the European Union and its implications for firms within and outside Europe
To explore the emergence of other integration agreements, especially in the Americas and Asia
To suggest corporate response to advancing economic integration
Deep Provision in Regional Trade Agreements: How Multilateral Friendly?(Febru...Ira Kristina Lumban Tobing
In recent years, many countries have actively sought to establish new bilateral and regional trade agreements (RTAs) to increase trade and spur economic growth. The current proliferation of RTAs reflects, in part, a demand for deeper integration than what has been achieved by older multilateral agreements. To the extent that they go beyond commitments made in the WTO and remain open to additional participation by countries committed to meeting their standards, RTAs can indeed complement the multilateral trading system.
The digitalization of the global economy has amplified the problem of tax avoidance and tax fairness and led to a rise in digital taxes around the world. This webinar seeks to discuss ways for East Africa to address two crucial issues:
Linking taxation rights to where value is created
Reforming the current corporate income tax system to disincentivize transfer pricing to the jurisdiction with the lowest tax rate.
Key Takeaways:
- Background of BEPS Conflict
- Recommendations and Measures in place
- Significance and impact of G7 Policy Decision
- Way forward on implementation
Key Takeaways:
- Background and Overview of Legal Provision
- Facts of the Case
- Contentions of the Assessee and Revenue
- Supreme Court’s Verdict
- Key Learnings and Way Forward
► Digital economy is raising complex issues for VAT systems
► OECD (November 2015): “International VAT/GST Guidelines” published with a heavy
focus on the place of supply of cross-border supplies of services and intangibles and the
application of the principles of destination and neutrality
► Trend toward digital supplies becoming taxable in the country of consumption
► Businesses increasingly needing to make VAT decisions in real time (at the point
of sale)
► Policymaking is developing – typical developments:
► Joint and several liability for online marketplaces
► Active searches for non-established ESS suppliers
► Removal of low value import thresholds
► Tax authorities are going digital
► Plus increasing inter-governmental cooperation
► Reputational risk rising
Taxes are the main source of income for governments as well as a powerful political tool worldwide. Globalization however has progressively opened the business transaction flows, regardless of borders or state lines. As such taxation on international corporations has become increasingly complex to regulate. The G20 will have to weigh the advantages and problems caused by corporations which seek banking abroad in order to avoid taxation. Written by Milain Fayulu and Helen Combes
Territorial Tax Systems: Motivations and Key Considerations For Effective ChangeRamon Tomazela
In this article, the author examines why some countries are moving to territorial tax systems, suggesting that they will need
comprehensive sourcing rules and a strong transfer pricing regime to ensure the transition is an effective approach to the challenges posed by today’s global economy.
The OECD's new work program would fundamentally change the way multinationals are taxed in the digital age, raising numerous questions of economic effects, compliance costs, and coordination between countries.
The four elements necessary for the OECD to be successful:
1.Identification of the scope and magnitude of the issues being addressed and how they are left unresolved by previous BEPS efforts.
2.A clear set of recommendations on both taxing rights and anti-base erosion policies that do the least amount of harm to economic growth.
3.Economic assessment of the potential impact of the policies on cross-border investment, cost of capital, foreign direct investment, compliance and administration costs, and countries’ tax revenue.
4.Commitment from countries to remove policies that conflict with the recommendations
Over the years, tax competition has led some countries to adopt more neutral, pro-growth business tax policies. This project could directly undermine that progress.
In partnership with the European Commission and World Bank Group, the Task Force on Tax and Development has developed a highly successful Transfer Pricing assistance programme in developing countries.
Tax management within multinational enterprises (MNEs) has never been more challenging. 'Getting to grips with the BEPS Action Plan' is the latest Grant Thornton report exploring the OECD’s planned overhaul of the international tax system, what it means for businesses and how they can prepare.
Presentation from the International Taxation session at the ICTD 7th annual meeting. The panel featured a discussion with Sol Picciotto, Alex Ezenagu, Michael Durst, Catherine Ngina Mutava, Martin Hearson, and Annet Oguttu.
We invite you to read our Regional Magazine AMERICA, in its 19° edition of April 2022, where you will find several regional articles of current topics, from the accounting and consulting sector; and on this occasion referred to the topic: "Global Markets".
Country-by-Country Reporting proposal - Working Breakfast 28 June 2016FERMA
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The European Confederation of Institutes of Internal Auditing (ECIIA) and FERMA stated that Internal auditors and risk managers have a key role to play in ensuring that future financial transparency standards are well understood, embedded into the strategy of large corporations and become a source of competitive advantage.
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Further information: http://oe.cd/tax-challenges-digital-impact-assessment
Understanding the Challenges of Street ChildrenSERUDS INDIA
By raising awareness, providing support, advocating for change, and offering assistance to children in need, individuals can play a crucial role in improving the lives of street children and helping them realize their full potential
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Many ways to support street children.pptxSERUDS INDIA
By raising awareness, providing support, advocating for change, and offering assistance to children in need, individuals can play a crucial role in improving the lives of street children and helping them realize their full potential
Donate Us
https://serudsindia.org/how-individuals-can-support-street-children-in-india/
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This session provides a comprehensive overview of the latest updates to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly known as the Uniform Guidance) outlined in the 2 CFR 200.
With a focus on the 2024 revisions issued by the Office of Management and Budget (OMB), participants will gain insight into the key changes affecting federal grant recipients. The session will delve into critical regulatory updates, providing attendees with the knowledge and tools necessary to navigate and comply with the evolving landscape of federal grant management.
Learning Objectives:
- Understand the rationale behind the 2024 updates to the Uniform Guidance outlined in 2 CFR 200, and their implications for federal grant recipients.
- Identify the key changes and revisions introduced by the Office of Management and Budget (OMB) in the 2024 edition of 2 CFR 200.
- Gain proficiency in applying the updated regulations to ensure compliance with federal grant requirements and avoid potential audit findings.
- Develop strategies for effectively implementing the new guidelines within the grant management processes of their respective organizations, fostering efficiency and accountability in federal grant administration.
Presentation by Jared Jageler, David Adler, Noelia Duchovny, and Evan Herrnstadt, analysts in CBO’s Microeconomic Studies and Health Analysis Divisions, at the Association of Environmental and Resource Economists Summer Conference.
ZGB - The Role of Generative AI in Government transformation.pdfSaeed Al Dhaheri
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Russian anarchist and anti-war movement in the third year of full-scale warAntti Rautiainen
Anarchist group ANA Regensburg hosted my online-presentation on 16th of May 2024, in which I discussed tactics of anti-war activism in Russia, and reasons why the anti-war movement has not been able to make an impact to change the course of events yet. Cases of anarchists repressed for anti-war activities are presented, as well as strategies of support for political prisoners, and modest successes in supporting their struggles.
Thumbnail picture is by MediaZona, you may read their report on anti-war arson attacks in Russia here: https://en.zona.media/article/2022/10/13/burn-map
Links:
Autonomous Action
http://Avtonom.org
Anarchist Black Cross Moscow
http://Avtonom.org/abc
Solidarity Zone
https://t.me/solidarity_zone
Memorial
https://memopzk.org/, https://t.me/pzk_memorial
OVD-Info
https://en.ovdinfo.org/antiwar-ovd-info-guide
RosUznik
https://rosuznik.org/
Uznik Online
http://uznikonline.tilda.ws/
Russian Reader
https://therussianreader.com/
ABC Irkutsk
https://abc38.noblogs.org/
Send mail to prisoners from abroad:
http://Prisonmail.online
YouTube: https://youtu.be/c5nSOdU48O8
Spotify: https://podcasters.spotify.com/pod/show/libertarianlifecoach/episodes/Russian-anarchist-and-anti-war-movement-in-the-third-year-of-full-scale-war-e2k8ai4
Jennifer Schaus and Associates hosts a complimentary webinar series on The FAR in 2024. Join the webinars on Wednesdays and Fridays at noon, eastern.
Recordings are on YouTube and the company website.
https://www.youtube.com/@jenniferschaus/videos
Up the Ratios Bylaws - a Comprehensive Process of Our Organizationuptheratios
Up the Ratios is a non-profit organization dedicated to bridging the gap in STEM education for underprivileged students by providing free, high-quality learning opportunities in robotics and other STEM fields. Our mission is to empower the next generation of innovators, thinkers, and problem-solvers by offering a range of educational programs that foster curiosity, creativity, and critical thinking.
At Up the Ratios, we believe that every student, regardless of their socio-economic background, should have access to the tools and knowledge needed to succeed in today's technology-driven world. To achieve this, we host a variety of free classes, workshops, summer camps, and live lectures tailored to students from underserved communities. Our programs are designed to be engaging and hands-on, allowing students to explore the exciting world of robotics and STEM through practical, real-world applications.
Our free classes cover fundamental concepts in robotics, coding, and engineering, providing students with a strong foundation in these critical areas. Through our interactive workshops, students can dive deeper into specific topics, working on projects that challenge them to apply what they've learned and think creatively. Our summer camps offer an immersive experience where students can collaborate on larger projects, develop their teamwork skills, and gain confidence in their abilities.
In addition to our local programs, Up the Ratios is committed to making a global impact. We take donations of new and gently used robotics parts, which we then distribute to students and educational institutions in other countries. These donations help ensure that young learners worldwide have the resources they need to explore and excel in STEM fields. By supporting education in this way, we aim to nurture a global community of future leaders and innovators.
Our live lectures feature guest speakers from various STEM disciplines, including engineers, scientists, and industry professionals who share their knowledge and experiences with our students. These lectures provide valuable insights into potential career paths and inspire students to pursue their passions in STEM.
Up the Ratios relies on the generosity of donors and volunteers to continue our work. Contributions of time, expertise, and financial support are crucial to sustaining our programs and expanding our reach. Whether you're an individual passionate about education, a professional in the STEM field, or a company looking to give back to the community, there are many ways to get involved and make a difference.
We are proud of the positive impact we've had on the lives of countless students, many of whom have gone on to pursue higher education and careers in STEM. By providing these young minds with the tools and opportunities they need to succeed, we are not only changing their futures but also contributing to the advancement of technology and innovation on a broader scale.
A Level Playing Field: The Need for non-G20 Participation in the BEPS' process
1. 1
A level playing field?
The need for non-G20 participation in the BEPS process
This paper is endorsed by the following organisations:
The Global Alliance for Tax Justice (coalition of 81
civil society organisations in 37 countries)
Tax Justice Network Africa
Tax Justice Network - Europe
ActionAid International
CCFD-Terre Solidaire (France)
CEDETRABAJO (Colombia)
Centre national de coopération au développement,
Coordinadora Civil de Nicaragua (alliance of 600
Nicaraguan civil society organisations)
CNCD-11.11.11 (Belgium)
Christian Aid (UK)
CIDSE (network of 17 Catholic development
organisations)
Finnwatch (Finland)
Global Policy Forum Europe
Halifax Initiative (Canada)
IBIS (Denmark)
Instituto Centroamericano de Estudios Fiscales
(Guatemala)
Instituto Justiça Fiscal (Brazil)
Inter Pares (Canada)
Jubilee South - Asia/Pacific Movement on Debt and
Development (JS-APMDD)
Jubileo 2000 Red (Ecuador)
Kairos Europe (Belgium)
Red Latinoamericana de Deuda, Desarrollo y
Derechos - LATINDADD
Methodist Tax Justice Network
Oxfam International
Red por la Justicia Tributaria en Colombia
(Colombia)
Tax Justice Network
Taxpayers Against Poverty (UK)
War on Want (UK)
World Economy, Ecology & Development - WEED
(Germany)
SUMMARY
multinational business marks a major and welcome change from previous defences of the
status quo.
Its Base Erosion and Profit Shifting (BEPS) project has the potential to initiate the most
significant international tax reforms for decades.
Yet while the OECD lobal comprehensive action p to tackle BEPS will
the process is currently excluding all
non-G20 countries, and thus most developing countries.
Technically too, the BEPS process is currently focussed on aspects of BEPS related to
-tech industries and digitalised consumer markets, while
-building. This risks overlooking
dysfunctions of the current int ,
and prevalent in sectors central to developing economies, including agribusiness, extractives
and telecoms.
Corporate Income Tax (CIT) nues,
quantitatively and administratively, than for developed countries . A process that
excludes the participation and interests of non-G20 economies will fail to safeguard the
interests of those countries most reliant on CIT.
Establishing an international tax settlement without the participation of the emerging
economies of the future risks repeating the dynamics behind the current fragmentation of
2. 2
international tax standards and practices.
While the participation of the BRICS economies is critical, it cannot be assumed that their
interests are synonymous with those of smaller non-G20 countries.
The BEPS process must include non-G20 countries.
Its objectives must include not only eliminating double non-taxation but also safeguarding
developing and capital- .
It should not be confined to tackling tax challenges generated by intellectual property, or the
omies.
RECOMMENDATIONS
Process
The OECD and the Working Group chairs (France, Germany the UK and the USA) must
ensure that non-G20 economies are able to participate fully in any re-write of the international
tax rules within the BEPS process.
Non-G20 countries involvement in BEPS may include:
! linking the three BEPS Working Groups to the work of the UN Tax Committee;
! incorporating nominees from the Task Force on Tax and Development in the BEPS
Working Groups and involving the Task Force in approval of the BEPS report but only if
the Task Force is able to undertake independent and representative decision-making.
The BEPS process must take the time needed to involve non-G20 economies, including
beyond the June reporting of the BEPS Working Groups.
Objectives
The success of the BEPS project should be judged both against its success in reducing
double non-taxation and aligning the tax base with economic substance, but also in
.
BEPS reforms should at least safeguard capital- (and prevent
round-tripping via tax havens, which distorts FDI flows), including by permitting countries to
enhance source taxation of cross-border income.
While it is not the role of the BEPS process to address domestic tax rates, it should offer
measures to reduce downward tax competition pressure driven by harmful and preferential
tax regimes, particularly in tax havens.
Solutions generated by the BEPS process should include measures applicable by all
countries, including less well-resourced tax administrations.
3. 3
A LEVEL PLAYING FIELD?
Corporate Income Tax is even more important for most developing countries than for
developed countries
i
is arguably of even more importance for the public
finances of developing economies than developed ones, for well-rehearsed reasons that include:
1) CIT constitutes
around 18% of tax receipts in low and lower-middle income countries, compared to 12.6% in
high-income countries;
ii
and compared to around 10% in the UK and 7% in the USA, for
example.
iii
Within the corporate tax base itself, multinationals are an even more significant source of CIT
receipts in developing countries than in developed countries. This corresponds with narrower
tax bases in general: large taxpayers across sub-Saharan African countries, for example,
typically constitute less than 5% of taxpayers and typically contribute three-quarters of all tax
revenues;
iv
in Kenya, just 0.01% of all taxpayers pay 50% of all VAT.
v
Necessary though efforts may be to broaden the tax base, they will need to avoid shifting the
tax burden to poorer taxpayers, and multinational CIT payments will continue to be rightfully
significant in the tax mix.
2) Administrability: Taxing business income at the level of the firm is administratively far more
straightforward than taxing it at the level of personal income tax. For this reason alone,
corporate profit tax is a hugely important tool for less well-resourced tax administrations.
3) International equity: taxing profits aims to ensure that business activities are taxed in the
place where resources are extracted, labour utilised, goods manufactured. This is critical for
developing economies. The most widely-discussed replacements for source-based or
residence-based CIT - sales-based methods of taxing business income - would do significant
economies.
vi
BEPS is a developing country problem too
The BEPS report acknowledges that "[m]ultinational enterprises (MNEs) are being accused of
dodging taxes worldwide, and in particular in developing countries, where tax revenue is critical to
foster long-term development".
vii
There is indeed strong evidence that profit-shifting is occurring as
much or more in non-OECD countries.
viii
Yet the BEPS report only addresses the issue of BEPS and
development in a single box on the very last page of the report.
ix
This box proposes that for
developing countries the BEPS problem is primarily one of capacity to apply the existing rules.
Much of the discussion and examples of base erosion and profit shifting given in the BEPS report has
likewise depicted the problem as primarily generated by two features characteristic of developed
-tech industries and digitalised consumer markets:
4. 4
- Intangibles: the difficulty of pricing returns to highly individual intangible assets, and the ease
with which such assets can
- E-commerce: online economic
activity -tax jurisdiction.
-tech industries are dominated by knowledge-based assets;
and that both online retail and digital business continue to be weighted towards Europe, the USA and
emerging markets in East and South Asia.
Asian subsidiaries of brewing
giant SABMiller has shown, profit-shifting via knowledge-based intangible assets relocated into tax
havens may be equally prevalent in far more traditional industries, for instance with consumer brands
or manufacturing processes.
-to- intra-group services,
for instance: as the new services article in the UN Model Treaty suggests, these are a particular issue
for multinationals in developing economies, often recruiting in overseas expertise for management
and other specialist functions, and often with management hubs located in tax havens.
Equally, tangible but company-specific intermediate products may be as difficult as to price as
intangible goods and services, similarly transferred through tax haven procurement hubs, and as
prevalent in the supply chains of breweries and agribusiness in the developing world as in
pharmaceuticals, aerospace or other high-tech industries.
Tackling BEPS thus cannot be confined to the digital economy and high-tech manufacturing: it can
and should also generate progress in those sectors central to developing economies - from
extractives to agribusiness to telecommunications.
Finally, as economies develop, they will face some of the same corporate tax challenges as G20
economies. Future-proofing any new settlement of international corporate tax requires the
participation of the emerging economies of the near future, not just those of the present.
Developing coun
economies
In tackling BEPS, it cannot be assumed that the interests of smaller non-G20 economies are always
synonymous with those of developed economies.
There will certainly be areas of common interest. These include greater transparency of multinationals
everywhere they operate, through requirements for combined and country-by-country reporting; and
tackling instances of double non-taxation where both developed and developing econo
may benefit. Perhaps perversely,
territorial t - , since much double non-taxation relies upon
the non-taxation of foreign-source income, as seen in Figure 1 (although territorialising tax systems
also increase incentives to shift foreign income to low-tax jurisdictions in the first place).
x
But some measures to prevent base erosion and profit shifting will inevitably involve a redistribution of
the tax base between countries with different kinds of economies and tax regimes. This is not to argue
that such measures are not globally desirable - but that international consensus on such measures
5. 5
must incorporate the interests of all countries, and agree on tools which safeguard different
An obvious example is the option of defending against profit-shifting by allowing more source
taxation of mobile income through withholding taxes where such income is taxed at very low
rates at its destination (Figure 2). This would be of great revenue benefit for developing
countries that are generally the net source rather than the destination of interest, royalties,
dividends and management fees; and would also help prevent profit-shifting from developed
countries into tax havens. Nonetheless developed countries levying low taxes on business
income like management fees (such as Ireland), or on IP royalties (such as the UK under its
venues on such income, after granting tax credits for
the withholding taxes levied at source.
Another example is the greater use of negotiated formulary methods, particularly those going
beyond transactional methods to allocate the profits of related entities as a whole. Such
methods may prevent abuse and bring better certainty to tax authorities and taxpayers alike.
But they will likely require negotiations over which factors sales, payroll, assets should be
given greater weight in profit allocation, especially as the growing use of bilateral or
multilateral advance pricing agreements (APAs) require agreements between tax authorities
-
India disputes over profit-splits have shown. Such negotiations may essentially entail
governments bargaining over whether countries of production or consumption should be
allocated greater taxable profits bargaining in which the relative power of each party may
mean that developing producer economies may not fare well, and may require rules or
.
6. 6
- stopping double non-taxation through hybrid entity
mismatch
xi
If Country S (developing country) imposes a withholding tax on dividends to hybrid entities, country C
(a developed country) does not lose tax revenue, since it has already exempted foreign intra-group
dividends; nor does country T (a tax haven), since it has already exempted foreign income.
xii
FIGURE 2: Redistribution of taxing rights - withholding taxes at source on cross-border
income subject to low taxes in the country of destination
10% WHT on royalties
Royalties income for patents qualify for
tax credit for WHT in country S, no more
more tax payable.
IP holding company
(Country R)
Operating subsidiary
(Country S)
RoyaltiesPurchase of IP
Low/no taxation of foreign income
Dividend income not subject to tax
(participation exemption or tax-
transparent entity)
Profit distribution to members (tax haven
holding companies) not subject to
withholding tax (WHT)
-S tax treaty.
Tax haven holding companies
(Country T)
Hybrid entity
(Country C)
Operating subsidiary
(Country S)
Profit distribution
Dividend
7. 7
FIGURE 3: Negotiation of taxing rights bilateral APA on formulary allocation of group profits
***
Some may fear that consensus will be difficult to reach if very diverse economic interests, beyond the
G-20, are represented around the table. But there is evidence that some developed countries are now
prepared to countenance some shifts of the international distribution of taxing rights in their own
enlightened self-interest: as suggested by the gradual movement towards taxation of services at
source, a provision for which is included in some existing tax treaties between OECD and non-OECD
economies, and is under discussion for the next draft of the UN model treaty; or by initiatives by
countries like the Netherlands to revisit tax treaties with developing countries to promote those
The OECD has been emphatic that BEPS is intended to deal with double non-taxation, not with wider
questions of the international allocation of the corporate tax base. But in practice the two are
inevitably linked, requiring all countries to be at the table.
The OECD has also argued that non-OECD countries are already being represented through the
invitation of the BRICS economies (Brazil, Russia, India, China and South Africa) as observers to the
the findings of the BEPS Working Groups.
xiii
But the interests of the BRICS cannot be taken as synonymous with those of all developing countries.
As growing capital exporters to smaller developing economies, they will increasingly play the role of
Tax authorities in country R and country
S negotiate over weight in allocation key
of sales, assets (intangible and
tangible?), payroll (headcount or
salary?), plus locational adjustments for
cheap labour or access to large consumer
market.
Holding company/R&D centre
(Country R)
Manufacturer/distribution centre
(Country S)
Royalties,
management fees
Payments for manufacturing
for distribution in both
country S and country R
R&D
IP
Large consumer
market
Low-cost labour
force
Plant/
machinery
8. 8
Recommendations: a BEPS process that delivers for all countries
We believe the significance of CIT for non-G20 countries, and the inevitable impact of BEPS solutions
process and
objectives.
Process
1. OECD members and particularly the BEPS Working Group chairs (France, Germany, the
UK and the USA) must ensure that Non-G20 economies must be able to participate fully in any
re-write of the international tax rules.
Within the OECD BEPS process, this may include linking the three BEPS Working Groups to
the work of the UN Tax Committee, which has wider developing-country participation and an
Troublingly, the only OECD forum with wide developing country participation, the Task Force
on Tax and Development, does not currently have BEPS on its formal agenda.
xiv
In any case,
its previous meetings have not had a formal mechanism for making decisions or ratifying
policies. The Task Force could be used to nominate non-G20 representatives from its 100+
members to the BEPS Working Groups, and to consider and ratify the BEPS document; but
only if it has independent and meaningful democratic structure and processes.
2. The process must take the time needed to involve non-G20 economies, particularly beyond
the June reporting of the BEPS Working Groups.
One obvious reason for confining the BEPS process to OECD+BRICS economies is its
breakneck speed, aiming to develop an Action Plan by June.
This ambition to make progress with real change is commendable after many years of near-
stasis in OECD tax rules. But proceeding rapidly without the participation of the emerging
economies of the future risks repeating the dynamics behind the current incipient
fragmentation of international tax standards and practices a fragmentation which lies behind
much of the current impetus towards reform.
Objectives
3. The success of the BEPS project should be judged both against its success in reducing
double non-taxation and aligning the tax base with economic substance, but also in
safeguarding
I interest to align the distribution of the corporate tax base more closely
with economic activity.
Within this objective, however, BEPS reforms should at least safeguard capital-importing
tax bases, including by permitting countries to enhance source taxation of cross-
border income, even if they may not have the redistribution of the corporate tax base from
global North to global South as their primary objective.
While it is not the role of the BEPS process to address domestic tax rates, it should offer
measures to reduce downward tax competition pressure driven by harmful and preferential
tax regimes, particularly in tax havens.
Solutions generated by the BEPS process should include measures applicable by all
countries, including less well-resourced tax administrations.
9. 9
NOTES
i
OECD, Addressing Base Erosion and Profit Shifting (2013), p. 8
ii
e latest available year). Oil-rich countries
(where oil and gas constitutes more than 25% of government revenues) generally derive an unusually high proportion of tax
receipts from this sector, and so have been excluded from both developed- and developing-country datasets.
iii
US Internal Revenue Service, Data Book 2009, Table 1 (http://www.irs.gov/pub/irs-soi/09databk.pdf); UK HMRC, HMRC Tax
and NIC Receipts (21 March 2013), p. 3 (http://www.hmrc.gov.uk/statistics/receipts/info-analysis.pdf)
iv
International Tax Dialogue, Revenue Administration in Sub-Saharan Africa (2010)
(http://www.itdweb.org/documents/AfricaStudy.pdf).
v
David Kloeden, Revenue Administration Reforms in Anglophone Africa Since the Early 1990s (IMF Working Paper
WP/11/162), July 2011, Table 5 (http://www.imf.org/external/pubs/ft/wp/2011/wp11162.pd). N.B. Data from 2006.
vi
See e.g. J. Mirrlees, S. Adam, T. Besley, R. Blundell, S. Bond, R. Chote, M. Gammie, P. Johnson, G. Myles and J. Poterba
(eds), Dimensions of Tax Design: the Mirrlees Review
vii
OECD, Addressing Base Erosion and Profit Shifting (2013), p. 13
viii
Christian Aid, Multinational corporations and the profit-shifting lure of tax havens (Occasional Paper No. 9), March 2013,
http://www.christianaid.org.uk/Images/CA-OP-9-multinational-corporations-tax-havens-March-2013.pdf; C Fuest, and N Riedel,
in P Reuter, Draining Development? Controlling
Flows of Illicit Funds from Developing Countries (World Bank, 2012), https://openknowledge.worldbank.org/handle/10986/2242
ix
OECD, Addressing Base Erosion and Profit Shifting (2013), p. 87, Box D.1
x
See, for example, the use of hybrid corporate entities in jurisdictions like the Netherlands as holding companies for
investments in developing countries: ActionAid Zambia/ActionAid UK, Sweet Nothings: the human cost of a British sugar giant
avoiding taxes in southern Africa (February 2013), pp. 25-26.
xi
For an example of this kind, see ActionAid Zambia/ActionAid UK, Sweet Nothings: the human cost of a British sugar giant
avoiding taxes in southern Africa (February 2013), pp. 25-26.
xii
This is obviously a simple example. Many hybrid entity mismatch situations will rely on tax consolidation to claim deductions
of e.g. interest in both jurisdictions.
xiii
ch
2013.
xiv
The Co-
forthcoming meetings focussing on capacity-
have noted that the OECD will very soon issue a report on Base Erosion and Profit Shifting (BEPS) and we look forward to