Base Erosion, Profit Shifting and Developing Countries

2016 ◽  
Vol 72 (3) ◽  
pp. 268 ◽  
Author(s):  
Ernesto Crivelli ◽  
Michael Keen ◽  
Ruud de Mooij
Keyword(s):  
Developing Countries ◽  
Profit Shifting

Simplification in Transfer Pricing

2021 ◽  
Vol 22 (3) ◽  
Author(s):  
Aitor Navarro
Keyword(s):  
Developing Countries ◽  
International Organizations ◽  
Transfer Pricing ◽  
Policy Option ◽  
Profit Shifting ◽  
Accepted Standard

It is the aim of this contribution to sustain that, despite the inherent complexity that the enforcement of the arm’s length rationale entails, it is feasible—and desirable—to introduce simplification measures without abandoning this worldwide accepted standard, especially in the context of developing countries and despite reticence shown by international organizations such as the OECD. Complexity in transfer pricing erodes fairness and equity and promotes profit shifting, which paradoxically constitutes the opposite outcome that this set of rules wants to achieve. This is the reason why it is urgent to propose and encourage the adoption of a means to neutralize unnecessary complexity in this field. The adoption of rebuttable predetermined margins and/or methods is proposed as the best solution in a context in which policymakers want to keep the arm’s length rationale intact. Also, even despite its shortcomings, irrebuttable predetermined safe harbors should be considered potentially feasible and a valid policy option.

scholarly journals Are Less Developed Countries More Exposed to Multinational Tax Avoidance? Method and Evidence from Micro-Data

2019 ◽  
Vol 34 (3) ◽  
pp. 790-809 ◽  
Author(s):  
Niels Johannesen ◽  
Thomas Tørsløv ◽  
Ludvig Wier
Keyword(s):  
Developing Countries ◽  
Multinational Firms ◽  
Tax Avoidance ◽  
Institutional Development ◽  
Developed Countries ◽  
Less Developed Countries ◽  
Tax Rates ◽  
Profit Shifting ◽  
Novel Approach ◽  
Data Requirements

Abstract This paper uses a global dataset with information about 210,000 corporations in 142 countries to investigate whether tax avoidance by multinational firms is more prevalent in less-developed countries. The paper proposes a novel approach to studying cross-border profit shifting, which has relatively low data requirements and is therefore particularly well-suited for the context of developing countries. The results consistently show that the sensitivity of reported profits to profit-shifting incentives is negatively related to the level of economic and institutional development. This may explain why many developing countries opt for low corporate tax rates in spite of urgent revenue needs and severe constraints on the use of other tax bases.

scholarly journals El proyecto BEPS y la planeación fiscal

2019 ◽  
pp. 37-50
Author(s):  
José Luis BÁRCENAS-PUENTE ◽  
Miguel Ángel ANDRADE-OSEGUERA
Keyword(s):  
Developing Countries ◽  
Multinational Enterprises ◽  
Large Scale ◽  
Tax Planning ◽  
Tax Burden ◽  
Profit Shifting ◽  
Fiscal Planning ◽  
The Law ◽  
The Way

Tax planning seeks, through the application of the law and other sources of law; reduce, eliminate or defer the payment of contributions; under this scheme, it is a lawful activity which constitutes a right for every taxpayer. However, the tax authority does not share this consideration and see decreased revenues as a result of these practices, describes them as illegal. To take out this type of strategy on a large scale, multinational enterprises have managed to reduce their tax burden, especially in developing countries; for this purpose, members of the OECD and the G-20 countries undertaken a series of actions known as "Project BEPS" (Base Erosion and Profit Shifting), in Spanish Base Erosion and location of utilities. This material is intended to expose the legality or illegality of fiscal planning, the contents of the BEPS project and the reactions of Mexico in this regard; in an analytical, critical and purposeful way through of the documental available sourses, using induction meanly. By the way, try it give a general panorama of the theme, providing elements of judgment of wich the reader can support this position.

scholarly journals OECD/G20 PILLAR TWO: IS IT A COMPATIBLE AND FEASIBLE SOLUTION?

2021 ◽  
Vol 5 (2) ◽  
pp. 136-149
Author(s):  
Vita Apriliasari
Keyword(s):  
Developing Countries ◽  
Literature Review ◽  
Feasible Solution ◽  
Profit Shifting ◽  
Two Measures

This study aims to contribute to the continuing discussion about the compatibility and feasibility of the OECD/G20 Pillar Two measures as a solution to address the remaining base erosion and profit-shifting (BEPS) issues. One triggering such a discussion is the significance of Pillar Two for developing countries. In so doing, a literature review is conducted to gain relevant considerations to the Pillar Two implementation. The analysis lead to the comprehension of the issues surrounding Pillar Two, i.e. justification, complicated design, fairness issues, and effectiveness.  

scholarly journals THE CONTEMPORARY INTERNATIONAL TAX SYSTEM, DEVELOPING COUNTRIES, BEPS AND OTHER CURRENT ISSUES / O SISTEMA TRIBUTÁRIO INTERNACIONAL CONTEMPORÂNEO, PAÍSES EM DESENVOLVIMENTO, BEPS E OUTRAS QUESTÕES ATUAIS

2018 ◽  
Vol 6 (7) ◽  
Author(s):  
Marcos Aurelio Pereira Valadão
Keyword(s):  
Developing Countries ◽  
International Organizations ◽  
The South ◽  
Profit Shifting ◽  
Tax System ◽  
Tax Systems ◽  
International Tax ◽  
Rich Countries

This paper analyzes the Contemporary International Tax System with focus on international tax cooperation, the participants of this context, that goes beyond the countries, and the issues that are present in base erosion and profit shifting (BEPS) Project with the focus on  those that are the most important for developing countries, also taking into consideration the Brazilian approach to those issues. It also verifies the role of international organizations (including NGOs), The paper consider other aspects, for example, the south Centre initiative on tax cooperation, and the biased approach from the northern rich countries towards the south poorer economies, coming to the conclusion that the differences between the needs of of developed and developing countries, which affect their tax systems, and the different tax systems itself, must be taken into account.

scholarly journals Base Erosion, Profit Shifting and Developing Countries

2015 ◽  
Vol 15 (118) ◽  
pp. 1 ◽  
Author(s):  
Ernesto Crivelli ◽  
Ruud A. Mooij ◽  
Michael Keen ◽  
◽  
◽  
...  
Keyword(s):  
Developing Countries ◽  
Profit Shifting

Some Aspects of the Architecture of International Tax Reform (and Their Human Rights–Related Consequences)

2019 ◽  
pp. 209-234
Author(s):  
Michael Lennard
Keyword(s):  
Developing Countries ◽  
Human Rights ◽  
Tax Reform ◽  
Tax Avoidance ◽  
Developed Countries ◽  
Profit Shifting ◽  
The Sustainable Development ◽  
Setting Mechanism ◽  
Development Goals ◽  
International Tax

This chapter looks at how the international tax norm-setting mechanism may positively or negatively affect attainment of the Sustainable Development Goals and the achievement of human rights. It is important to recognize that there is a great deal of concern expressed by many developing countries about their lack of real participation in the development of what are being promoted as global tax norms or standards. The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project has brought some of these issues to the forefront. Nevertheless, there is much that is useful to developing countries in the BEPS outcomes, especially in combatting what is commonly regarded by both developing and developed countries as tax avoidance or evasion, such as through international profit-shifting.

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