The Base Erosion and Profit Shifting (BEPS) Project was initiated by the Organization for Economic Co-operation and Development and G20 in 2013 to address tax avoidance schemes used by... Show moreThe Base Erosion and Profit Shifting (BEPS) Project was initiated by the Organization for Economic Co-operation and Development and G20 in 2013 to address tax avoidance schemes used by multinational enterprises (MNEs). Drawing on interviews with a range of tax policy stakeholders, this book analyses the BEPS Project’s impact on developing countries’ approaches to combatting international tax avoidance, developing novel typologies to categorize policies and conducting case studies in Colombia, India, Nigeria, and Senegal. Contrary to public communication surrounding it, the BEPS Project does not endorse any kind of approach against tax avoidance, but puts an emphasis on finely delineating responses rather than blunt measures to tackle the problem. However, blunter approaches have been used more often by developing countries due to limited administrative resources. Examining countries’ responses, this research uncovers that the BEPS Project has influenced approaches to transfer pricing, albeit with delays and varied enforcement. The study also reveals discrepancies in addressing treaty shopping, showcasing measures beyond BEPS recommendations that countries adopt when revenue losses are high. The findings further show that the interplay between different governmental departments is pivotal in shaping policy responses to tax avoidance. Show less
Calderoni, A.; Cubillos González, J.; Heitmüller, F. 2022
Corporate taxation and particularly corporate tax incentives that jurisdictions introduce in special economic zones have not, until recently, been subject to extensive international regulation.... Show moreCorporate taxation and particularly corporate tax incentives that jurisdictions introduce in special economic zones have not, until recently, been subject to extensive international regulation. Only in the last decade has a regime of soft law standards and European Union measures with extraterritorial effect been constructed. This article explains how the Base Erosion and Profit Shifting Action Plan developed by the Organisation for Economic Co-operation and Development (OECD) and the European Union Code of Conduct for Business Taxation interact with corporate tax incentives in special economic zones. Empirical evidence from Latin American and Caribbean jurisdictions shows that this emerging international regime began having an impact on special economic zone laws beyond the OECD and European Union Member States. An analysis of ongoing negotiations on the further developments of the international tax regime permits the cautious conclusion that the regulation of SEZs may in the future be affected in a more fundamental manner by international norms. Thereby, the article shows that special economic zones’ unilateralism in corporate taxation may be slowly receding in contrast to other areas of international economic governance. Show less
