Taxing Multinationals 'Post-BEPS' - What's Next?

The taxation of multinational companies has been attracting a great deal of attention in recent years. Com- pany tax planning and country tax competition have increasingly been questioned, by the general public, media, in politics and academia. Countries compete for investment, reducing tax burdens on profits. Multinationals respond, shifting profit for tax purposes to low- tax jurisdictions by legally arranging their business affairs in a certain way to optimise their effective corporation tax burdens. Globalisation speeds-up matters. The company taxation models that countries apply today originated in the 1920s. These models were of course designed to cater for interbellum societal, political, economic and business realities, and hence no longer seem ‘fit -for -purpose’ in today’s globalised market place. Corporate tax systems are antique and now appear to be failing, in consequence putting fiscal systems under pressure. The OECD has estimated missed corporate tax revenues at a staggering 1⁄4 of a trillion US dollars a year. To balance budgets, countries resorted to raising tax burdens on consumption and labour. Economic and financial crises that we now seem to have overcome have exacerbated matters, affecting societal trust in the integrity of the tax system. The general pub- lic considers tax bill increases unfair if they are not addressed to multinationals, but imposed on their work- ers and customers instead. It is often heard that moral obligations to finance expenditure apply equally to multinationals.

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