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.
Geopolitical rivalry is reshaping global tax cooperation, as the OECD’s minimum tax framework fragments and the EU grapples with the ensuing legal fallout
Chile’s revamped GAAR marks a shift toward structural scrutiny, pushing MNEs to strengthen tax governance, economic substance and compliance strategies
While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model