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Reflections on the OECD’s action plan on BEPS

The OECD will have to tread a delicate path between maximising tax harmonisation to enhance the effectiveness of new standards and not alienating governments protective of their fiscal sovereignty, explain Martin Zetter and Nigel Doran

The fundamental objective of the OECD’s Action Plan on Base Erosion and Profit Shifting (‘the plan’) is to frustrate practices which prevent profits being taxed in the countries in which the activities generating them take place (the ‘territoriality principle’). This will be achieved by new international standards ensuring coherence of corporate income taxation preventing abuse of standards and enhancing transparency.

International coherence of corporate income taxation

Digital economy

Detailed options will be developed addressing the difficulties of applying international (direct and indirect) tax rules to the digital economy. Digital businesses do not need a tax nexus with countries where they generate sales and attributing value appropriately is problematic. The...

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