On February 13 2013, the OECD released a report on tax planning by multinationals that reduces group corporate tax liability to an unacceptably low level, as a first step against base erosion and profit-shifting (BEPS). In the preceding months Starbucks, Google and several others were publicly attacked for not paying their “fair” share. Johann Muller, a member of the international corporate taxation department at the Danish Tax Authority – submitting this article in a personal capacity in advance of the OECD Working Party No 6 meeting in March – examines the issues that need to be addressed when looking at examples 1 and 2 to Annex C of the BEPS report.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Scott Bessent reportedly felt undermined by Musk naming Gary Shapley as acting IRS commissioner; in other news, Baker Tilly will combine with a top 15 US firm
Despite garnering significant revenues from multinationals, Italy’s digital services tax presents pressing double taxation issues, say Stefano Simontacchi and Francesco Saverio Scandone of BonelliErede