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So, best I can tell, neither the OECD's base erosion and profit shifting work nor the U.S. [TCJA] tax reform, will end the ability of major U.S. companies to reduce their overall tax burden by aggressively shifting profits offshore (and paying between 0 [and] 3 percent on their offshore profits and then being taxed at the GILTI 10.5 percent ...
The OECD G20 Base Erosion and Profit Shifting Project (or BEPS Project) is an OECD/G20 project to set up an international framework to combat tax avoidance by multinational enterprises ("MNEs") using base erosion and profit shifting tools. [5]
The organisation also attempted to limit companies’ ability to shift profits to low-tax locations, a practice known as base erosion and profit shifting (BEPS). [1] [2] The goal of this worldwide exchange of tax information being tax transparency, it requires the exchange of a significant volume of information.
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting, sometime abbreviated BEPS multilateral instrument, is a multilateral convention of the Organisation for Economic Co-operation and Development to combat tax avoidance by multinational enterprises (MNEs) through prevention of Base Erosion and Profit Shifting (BEPS).
Hines-Rice felt the variations between havens was too material for a single definition, beyond a requirement for low effective tax rates; distortions from profit shifting led them to note proxies, including: the GDP-per-capita proxy, and the corporate profitabity proxy; [11] in June 2018, these tools were used to show that Ireland was the ...
The United States joined the talks of the OECD/G20 group on (tax-) Base Erosion and Profit Shifting in 2020, and in April 2021, Janet Yellen, the United States Treasury Secretary, agreed with the Franco-German proposal. [12]
These are called base erosion and profit shifting (BEPS) techniques. [93] Notable BEPS tools like the Double Irish with a Dutch Sandwich were used by US corporations to build up untaxed offshore cash reserves of US$1–2 trillion in tax havens like Bermuda (e.g., Apple's Bermuda Black Hole ) from 2004 to 2017. [ 196 ]
Zucman is also known for his work on the quantification of the financial scale of base erosion and profit shifting (BEPS) tax avoidance techniques employed by multinationals in corporate tax havens, [11] [12] through which he identified Ireland as the world's largest corporate tax haven in 2018. [13]