When work on the taxation of the digital economy kicked off as part of the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project in late 2018, there seemed to be a broad agreement that international tax rules needed an overhaul to successfully tax billion dollar tech giants like Amazon, Google and Facebook. Key to this…
Read moreDeveloping countries lose substantial revenues every year to corporate tax avoidance, exacerbated by globalization and digitalization. As part of the OECD/G20 project on addressing the tax challenges of the digitalization of the economy, the OECD secretariat have recently presented the Unified Approach (UA) to deal with the tax revenue losses from digitalization, by giving market…
Read moreThe advent of digitalised business models has considerable potential to improve trade in Africa, however, it has greatly exacerbated the two central challenges of international tax. The first challenge is the definition of taxable presence, and the second is the allocation of business profits of multinational enterprises (MNEs) among the different jurisdictions where they operate….
Read moreThe OECD secretariat recently proposed a “stock taking exercise” to “re-examine how international tax rules currently meet the needs of developing countries” leading potentially to a “new deal on international taxation as part of the international effort to rebuild economic life in the post Covid-19 era.” The OECD’s Pascal Saint-Amans has suggested that this may…
Read moreIn the wake of the global financial crisis of 2007-08, tax havens became a hot topic as political leaders zeroed in on exotic, low-tax jurisdictions as sources of fiscal instability that exacerbated the crisis. With the Covid-19 pandemic, tax havens have been even more immediately and strongly linked to the crisis and the prospects for…
Read moreWe could be in the midst of the biggest change to the way multinational companies are taxed in decades. In January 2019, over 130 developed and developing countries committed to ‘go beyond’ some of the fundamental principles that have underpinned cooperation on corporate taxation for a century (OECD 2019a). They opened negotiations to redistribute ‘taxing…
Read moreThe global fight over how—and where—to tax the new digital economy is raging on. Just last week, the Office of the US Trade Representative (USTR) published the conclusions from its investigation into France’s new tax on large tech companies, such as Apple, Facebook, and Google. The USTR found that the French tax discriminates against US companies, and…
Read moreDeveloping countries are making a significant contribution to the current efforts to reform international tax in the project on base erosion and profit shifting (BEPS), despite the obstacles they face in making their participation effective. It is welcome that since 2016 participation in the process was open to all countries, through the Inclusive Framework on…
Read moreIn her recent blog, Allison Christians usefully alerts us to some of the challenges and opportunities of the new rules on international taxation being negotiated at the OECD. However, it is important to shed some additional light on the dynamics and context of the Inclusive Framework process. The acute tensions we see in the international…
Read morePress Release Today, the G20 Finance Ministers are meeting in Washington D.C. to consider the OECD’s proposal for a “unified approach” to update international corporate tax rules for the digital era. Following its publication last week, the proposal was described as stunning, revolutionary, and a “global shake-up.” But how radical is it really, and how…
Read moreWhen the OECD’s ‘Inclusive Framework’ invited public input on the possible solutions to the tax challenges of digitalization in February 2019, there was some enthusiasm that the renewed effort would address the overall imbalance in the allocation of taxing rights. The hard and soft law of international tax rules prevents countries taxing multinational enterprises (MNEs)…
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