Thursday, August 28, 2014
Richard J. Vann (Sydney), Policy Forum: The Policy Underpinnings of the BEPS Project-Preserving the International Corporate Income Tax?, 62 Canadian Tax J. 433 (2014):
The OECD/G20 Action Plan on Base Erosion and Profit Shifting (BEPS) is receiving significant attention from taxpayers and national governments. Because the action plan is about action, it contains little discussion of the tax policy questions involved. One of the less-noticed aspects of the plan is action 11. From its heading and most of its content, action 11 seems to be largely about collecting data on BEPS, but it also involves the underlying policy. That is perhaps not surprising, since there is an inherent contradiction between the action plan and much of the policy work on corporate taxation undertaken by the OECD over the last 25 years. This article discusses the policy conflict and make the case for a more balanced view of the international corporate income tax.