Addressing base erosion and profit shifting

Description

Base erosion constitutes a serious risk to tax revenues, tax sovereignty and tax fairness for many countries. While there are many ways in which domestic tax bases can be eroded, a significant source of base erosion is profit shifting. This report presents the studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters and identifies the key principles that underlie the taxation of cross-border activities, as well as the BEPS opportunities these principles may create. The report concludes that current rules provide opportunities to associate more profits with legal constructs and intangible rights and obligations, and to legally shift risk intra-group, with the result of reducing the share of profits associated with substantive operations.  Read more... Vsebuje tudi: 1. Introduction -- 2. How big a problem is BEPS? An overview of the available data -- 3. Global business models, competitiveness, corporate governance and taxation -- 4. Key tax principles and opportunities for base erosion and profit shifting -- 5. Addressing concerns related to base erosion and profit shifting -- Annex A. Data on corporate tax revenue as a percentage of GDP -- Annex B. A review of recent studies relating to BEPS -- Annex C. Examples of MNE's tax planning structures -- Annex D. Current and past OECD work related to base erosion and profit shifting.