November 2015
Publication

Measuring Misalignment: the Location of US Multinationals’ Economic Activity Versus the Location of their Profits

by Alex Cobham & Petr Janský

A major international effort – the OECD Base Erosion and Profit Shifting (BEPS) initiative aims to reduce the extent of misalignment between the profits of multinational groups, and the location of their real economic activity. Recent research using balance sheet data has shown major misalignments, with a number of small jurisdictions capturing a tax base…

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Blog

OECD plan means governments no longer taxing in the dark

Two years on from a project triggered by scrutiny of the “successful” tax avoidance structures of multinationals such as Apple, Google and Microsoft, the OECD has delivered its final package of reforms on Base Erosion and Profit Shifting (BEPS). Is the BEPS project a success? The answer is as elusive as the answer to the classic question “is the…

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November 2014
Publication

International Distribution of the Corporate Tax Base: Implications of Different Apportionment Factors under Unitary Taxation

by Alex Cobham & Simon Loretz

Under the current system of separate accounting, tax-motivated international profit shifting results in misalignment of profits and real economic activity. While the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting initiative aims to measure and curtail this, critics claim serious progress is only possible with greater emphasis on formulary apportionment methods…

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