The transfer pricing practices of multinational enterprises have become a subject of intense political focus throughout the world. How did we get here and what needs to change?
International taxation is a subject typically far from public media and political discussion. This has changed dramatically in recent months with highly-publicised legislative hearings in the UK and US involving name brand multinational enterprises (MNEs). The G8 and G20 have demanded that so-called ‘base erosion and profit shifting’ be addressed by the Organisation of Economic Cooperation and Development viewed as the arbiter of guidelines for such matters. The BRIC countries as well as emerging and developing countries are likely to have their own agendas.
The usually arcane world of international taxation has two principal technical components:
