Open Access. Powered by Scholars. Published by Universities.®
Articles 1 - 2 of 2
Full-Text Articles in Entire DC Network
Beps - A Primer On Where It Came From And Where It’S Going, Jeffrey M. Kadet
Beps - A Primer On Where It Came From And Where It’S Going, Jeffrey M. Kadet
Articles
Governments throughout the world have been losing many billions of dollars of tax revenues from “legal” tax avoidance conducted by many multinational groups (MNEs) through aggressive structuring of operations and transactions that often lack economic reality so as to earn profits that are subjected to zero or low-taxation. The success of this “legal” tax avoidance motivated the G-20 and the OECD to initiate the two-year Base Erosion and Profit Shifting (BEPS) project, which took place from 2013 to 2015.
This discussion of the BEPS project is intended to give the reader an understanding of the project’s origin, its objectives, and …
Expansion Of The Profit-Split Method: The Wave Of The Future, Jeffrey M. Kadet
Expansion Of The Profit-Split Method: The Wave Of The Future, Jeffrey M. Kadet
Articles
Recognizing the reality that multinational corporations are centrally managed and not groups of entities that operate independently of one another, the OECD base erosion and profit-shifting project is considering expanded use of the profit-split method. This article provides background on why expanded use of the profit-split method is sorely needed. In particular, resource-constrained tax authorities in many countries are unable to administer or intelligently analyze and contest transfer pricing results presented by multinational groups. Most importantly, this article suggests a simplified profit-split approach using set concrete and objective allocation keys for commonly used business models that should be welcomed by …