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Contributions of the Base Erosion and Profit Shifting BEPS Project on Transfer Pricing and Tax Avoidance [PDF]
Globalization and digitalization lead to flaws and asymmetries in tax rules which were used by multinational companies in their own benefit. Then, to face tax avoidance and tax losses which represents 100 to 240 billion dollars per year, Organization for
Anissa Ouelhadj, Mehdi Bouchetara
doaj +4 more sources
Tax as the main source of income for the state has an important role in financing sustainable development. However, the dynamics of tax planning are increasingly complex with the issue of Base Erosion and Profit Shifting (BEPS), which has become a major ...
Fitri Pebriani Wahyu +1 more
doaj +2 more sources
The Multilateral Instrument: Avoidance of Permanent Establishment Status and the Reservations on behalf of Australia and the UK [PDF]
This paper considers fully probabilistic system models. Each transition is quantified with a probability—its likelihood of occurrence. Properties are expressed as automata that either accept or reject system runs. The central question is to determine the
Ivanova, Milla
core +7 more sources
Retos de la potestad tributaria en México respecto al impuesto sobre la renta en la economía digital
La economía digital ha tenido un profundo impacto en la tributación, pues la deslocalización de los establecimientos y la rapidez de su evolución han propiciado la erosión de las bases y traslado de beneficios de las grandes multinacionales, siendo esta
Miguel Ángel Haro Ruiz +2 more
doaj +1 more source
Profit shifting in Brazil and the impact of tax havens
We investigate tax-induced profit shifting in Brazil and the impact of tax havens on the shifting behavior of firms. Profit shifting research in Brazil is virtually non-existent, although the shifting incentives in Brazil are prominent.
Alex A. T. Rathke
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A Positive Dialectic: Beps and The United States
This essay addresses the interaction between the changes in the international tax regime identified by Mason and U.S. international tax policy. Specifically, I will argue that contrary to the general view, the United States actively implemented the ...
Reuven S. Avi-Yonah
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The necessity of conducting research in the direction of forming the Report in terms of countries of the international group of companies has been determined.
S.F., I.V.
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AbstractBinding taxpayer-initiated international dispute resolution has traditionally played a minor role in the international tax system. Despite being long pursued by corporate interests and increasingly accepted by developed countries, international tax arbitration has remained less developed and less respectful of private interests than investor ...
Chris Noonan, Victoria Plekhanova
openaire +1 more source
The Tax Sensitivity of Debt in Multinationals: A Review [PDF]
The OECD in its BEPS action plan 4 addresses tax base erosion by profit shifting through the use of tax deductible interest payments. Their main concern is interest deductions between outbound and inbound investment by groups.
Schjelderup, Guttorm
core +3 more sources
This article provides an overview of China’s reaction to the G20/OECD Base Erosion and Profit Shifting (BEPS) project. From 2013 to 2015, the OECD developed a series of actions designed to address BEPS activities by multinational enterprises, culminating
Reuven Avi-Yonah, Haiyan Xu
doaj +1 more source

