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The New International Tax Regime, Reuven S. Avi-Yonah
The New International Tax Regime, Reuven S. Avi-Yonah
Law & Economics Working Papers
On October 8, 2021, over 130 countries committed themselves to the most far-reaching changes in the international tax regime since its inception in 1923. Slated to begin on the anniversary year of 2023, this new regime (ITR 2.0) adopts significant changes from the old one (ITR 1.0). Specifically, ITR 2.0 eliminates the physical presence requirement and the arm’s length standard for a significant portion of the profits of large multinationals that have been essential elements of ITR 1.0 since the 1930s, in a way that is more consistent with ITR 1.0’s Benefits Principle (BP). ITR 2.0 also explicitly implements the …
International Tax Law- Status Quo, Trends And Perspectives, Reuven S. Avi-Yonah
International Tax Law- Status Quo, Trends And Perspectives, Reuven S. Avi-Yonah
Law & Economics Working Papers
This chapter will argue that developments in the past decade have significantly bolstered the International Tax Regime, so that it does a much better job in protecting PIT and CIT from erosion due to cross-border tax evasion and avoidance than it did before 2010. Specifically, the adoption of FATCA and the consequent development of Automatic Exchange of Information (AEI) and the Common Reporting Standard (CRS) have significantly protected PIT, while the OECD BEPS project has significantly improved CIT, especially if the current BEPS 2.0 effort is successfully concluded.