Category BEPS

The new political economy and geography of global tax information exchange

The OECD has recently released information on the two most important recent global networks of global tax information exchange. They are, respectively, the networks of exchange of country-by-country reporting (CBCR) and exchange of financial account information (through the Common Reporting Standard, CRS). These networks give a unique look into the new political economy and geography of […]

Technical politics, sovereignty and the prospects of tax multilateralism

International tax cooperation is hard. Especially when it challenges national sovereignty. Sovereignty is close to heart for politicians. Taxation remains a cornerstone of the nation-state and of the social contract. Governments are not liable to relinquish absolute authority on tax matters. So, at least, the story goes. Indeed, the reality – and the associated perception – of taxation […]

The quiet BEPS revolution: Moving away from the separate entity principle

For the longest time, international law has treated multinational enterprises (MNEs) as consisting of separate, independent units, rooted in separate national jurisdictions. Apple’s US corporate headquarters is distinct from its Irish holding company, which is distinct from its local national subsidiaries – even though they are all part of the same multinational group. Their reporting compliance and tax liabilities are, […]

Technicised BEPS: How complexity shapes politics

On June 4, the OECD released public comments received on Action 15 of the OECD/G2o Base Erosion and Profit Shifting (BEPS) project, which concerns the development of a multilateral instrument for modifying bilateral tax treaties in order to implement treaty-related BEPS recommendations.

Revolving doors in international tax: Do the foxes run the henhouse?

In trying to explain the most recent financial crisis and what is perceived to be ongoing struggles to properly regulate markets and economic behavior, a popular sentiment among political commentators has been to blame ‘revolving doors’. Revolving doors is now a mainstream term meaning professionals’ strategic career moves between the public and private sector. Typically, such moves are […]