The problem of base erosion and profit shifting (BEPS) has been addressed by the OECD/G20 Action Plan (the BEPS Project) initiated in 2013,2 which resulted in 15 Reports in 2014-15,3 followed in 2018 by the Interim Report on Tax Challenges Arising from Digitalization,4 leading to a final document “Inclusive Framework on BEPS” released in 2019.5 Both the BEPS Project and the Inclusive Framework consider BEPS primarily as a problem to be addressed through new measures aimed at stop-gapping or countering aggressive tax strategies pursued by multinational enterprises (MNEs) and/ or allocating tax claims on the basis of a concept of “value creation”.
Tax sustainability and residence-based global taxation of MNEs
garbarino
2020
Abstract
The problem of base erosion and profit shifting (BEPS) has been addressed by the OECD/G20 Action Plan (the BEPS Project) initiated in 2013,2 which resulted in 15 Reports in 2014-15,3 followed in 2018 by the Interim Report on Tax Challenges Arising from Digitalization,4 leading to a final document “Inclusive Framework on BEPS” released in 2019.5 Both the BEPS Project and the Inclusive Framework consider BEPS primarily as a problem to be addressed through new measures aimed at stop-gapping or countering aggressive tax strategies pursued by multinational enterprises (MNEs) and/ or allocating tax claims on the basis of a concept of “value creation”.File | Dimensione | Formato | |
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2020 Tax sustainability and residence-based. tax of MNEs.pdf
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