The OECD’s Base Erosion and Profit Shifting (BEPS) project issued a report in February 2013, which confirmed that the present international tax rules are not effective: “There is increased segregation between the location where actual business activities take place and the location where profits are reported for tax purposes.” David Spencer, formerly a senior adviser and head of transfer pricing for the Tax Justice Network, explores the viability of unitary taxation and questions whether it is a realistic option, considering the way international commerce operates.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
Foreign companies operating in Libya face source-based taxation even without a local presence. Multinationals must understand compliance obligations, withholding risks, and treaty relief to avoid costly surprises
Tax professionals are still going to be needed, but AI will make it easier than starting from zero, EY’s global tax disputes leader Luis Coronado tells ITR
The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations