Digging into Caterpillar and BEPS: Economic substance and location

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

Digging into Caterpillar and BEPS: Economic substance and location

April 29 2014
caterpillar.jpg

In the second part of her analysis of Caterpillar’s tax affairs following the company’s appearance before the Senate Subcommittee on Investigations, Mirna Screpante, tax researcher, looks at the division between the location of activities and the location of taxable profits and proposes a method for determining economic substance.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Request Access or Login

Topics

News Direct Tax Europe United States (National) Switzerland
more across site & shared bottom lb ros

More from across our site

Direct Tax
Kelowna,,British,Columbia,,Canada,-,August,16,,2025:,Kpmg,Sign
KPMG Australia shields tax team as nearly 400 roles axed
Despite the ongoing audit controversy, the firm’s tax and legal division saw revenue growth of 10.9%
Sam Sholli, August 24 2026
Direct Tax
UN headquarters New York
Beyond the headlines: UN tax convention on track despite OECD countries’ heel-dragging
Fresh from the UN negotiations in New York, Alex Cobham offers ITR readers a rare first-hand perspective on the future of international tax cooperation
Alex Cobham, August 24 2026
Direct Tax
kpmg.jpg
KPMG Australia tax team survives job cuts amid audit scandal: report
Around 450 client-facing roles are due to be axed next week, it has been reported
Sam Sholli, August 21 2026
Direct Tax
Moscow,,Russia,01.02.2025,Democratic,Party,Usa,Flag,Badge
A taxing week: Expect no pillar two favours from a Democratic administration
The OECD may be making a mistake if a 2029 review is intended to outlast Trump in the hope of more favourable treatment from the US Democrats
Sam Sholli, August 21 2026
Transfer Pricing
India investment
Indian advisory firm Nexdigm strikes partnership with AI-enabled TP platform
Nexdigm has invested in Singapore-based infer360, a TP intelligence product designed by ex-PwC partners
Tom Baker, August 21 2026
Awards
itr americas awards 2026 col@4x.png
ITR Americas Tax Awards 2026: shortlist announced
ITR is delighted to reveal all the shortlisted nominees for the 2026 Americas Tax Awards
John Harrison, August 20 2026
Indirect Tax
Brazil.jpg
The hidden compliance risk in Brazil's VAT enforcement delay
Despite initial hopes that the reporting obligation had been suspended, compliance challenges brought by Brazil’s indirect tax reform are very much a reality
Sam Sholli, August 20 2026
Direct Tax
Latin America map
The Latin American tax policy landscape in 2026: an overview
As tax authorities embrace AI and governments weigh pillar two reforms, Latin America is developing a more connected and internationally focused tax agenda
Lucas de Lima Carvalho, August 19 2026
Direct Tax
hmrc.jpg
HMRC launches second tax adviser registration phase
Advisers with pre-existing corporation tax or self-assessment accounts must now register or risk enforcement action from HMRC
Tom Baker, August 18 2026
Direct Tax
india.jpg
The increasing importance of ‘economic substance’ under Indian income tax laws
India's tax authorities are increasingly scrutinising the rationale behind cross-border structures
Sanjay Sanghvi, August 18 2026
Gift this article