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
Corporate taxation has become an important topic of public debate and corporate tax planning has met with strong societal criticism. In response to these societal concerns, the Organization for... Show moreCorporate taxation has become an important topic of public debate and corporate tax planning has met with strong societal criticism. In response to these societal concerns, the Organization for Economic Co-operation and Development (OECD) launched the OECD/G20 BEPS project. In light of these developments, research on the professional practice of corporate tax planning has become more relevant. In this book, the author investigates tax professionals’ reactions to changing societal expectations of corporate tax planning. Taking a qualitative approach, the responses of different types of tax professionals of the Dutch corporate tax field were examined. Particular attention was paid to the manner in which tax professionals understand corporate tax planning and the public discussion, to what degree societal norms influence the professional practice of corporate taxation, and to what degree tax professionals have altered their role perceptions in response to public concerns of corporate tax planning. Show less
In this article, the authors discuss the implications of their study on the effectiveness of the Multilateral Instrument (MLI). Their analysis finds that there are 79 parties to the MLI and that... Show moreIn this article, the authors discuss the implications of their study on the effectiveness of the Multilateral Instrument (MLI). Their analysis finds that there are 79 parties to the MLI and that the MLI covers 1,231 tax treaties and that the OECD currently overreports the effectiveness of the MLI. Show less
In the Netherlands, levying tax on inheritances at death has been a fact of life for centuries. The presumed double taxation and its sad precursor are elements of the discussion about the levy of... Show moreIn the Netherlands, levying tax on inheritances at death has been a fact of life for centuries. The presumed double taxation and its sad precursor are elements of the discussion about the levy of this inheritance tax, but so too are the possibilities to reduce the tax through ingenious legal constructions. In its zeal to counter such clever plans the legislature has turned the law into a complex body without parrying all the avoidance behaviour. On top of that, the effects of the current law can be very unreasonable. The thesis uncovers the root cause of this problem by retracing the levy of inheritance tax to the Republic of the Seven United Netherlands, a little-described chapter in legal history. It is discovered how the current problems would never have occurred under the simple statutory provision applicable in that period. The obvious conclusion is that the inheritance tax should be reformed based on that model. How such amendment can best be designed is elaborated further based on insights gained from legal history and other legal systems. This has resulted in a complete bill with comments, so the legislature now has the solution at its fingertips. Show less
