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Articles 1 - 3 of 3
Full-Text Articles in Law
Reactions To Hybrid Mismatch Arrangements And Strategy Suggestions For Korea, Aju Nam
Reactions To Hybrid Mismatch Arrangements And Strategy Suggestions For Korea, Aju Nam
Maurer Theses and Dissertations
In recent years, the Organisation for Economic Co-operation and Development (OECD)’s Base Erosion and Profit Shifting (BEPS) project has been one of the biggest issues in international taxation. The OECD refers to BEPS as “tax avoidance strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations.” In 2014, the OECD released BEPS Action 2 as responds on Hybrid Mismatch Arrangements (“HMA”s), which are arrangements exploiting differences in the tax treatment of instruments, entities or transfers between two or more countries. Two of the major factors of HMAs are hybrid entities and hybrid …
Taxation, Competitiveness, And Inversions: A Response To Kleinbard, Michael S. Knoll
Taxation, Competitiveness, And Inversions: A Response To Kleinbard, Michael S. Knoll
All Faculty Scholarship
In this report, I argue that the inversion situation is more nuanced, complex, and ambiguous than Edward D. Kleinbard acknowledges, and I challenge Kleinbard’s claim that U.S. multinationals are on a tax par with their foreign competitors.
The Global Fight Against Base Erosion And Profit Shifting Under The Oecd’S Country-By-Country Reporting Rules: A Possible Solution?, Oladiwura Ayeyemi Eyitayo-Oyesode
The Global Fight Against Base Erosion And Profit Shifting Under The Oecd’S Country-By-Country Reporting Rules: A Possible Solution?, Oladiwura Ayeyemi Eyitayo-Oyesode
LLM Theses
The base erosion and profit shifting (BEPS) phenomenon continues to create detrimental consequences in states. BEPS is engendered by two fundamental factors, namely, unhealthy fiscal policies of tax havens and preferential tax regimes, and transfer mispricing by multinational corporations (MNCs). The OECD, through its BEPS Project notes that the lack of transparency in the global activities of MNCs is a major cause of BEPS. To close this gap, the OECD released the CBCR Rules. This thesis discusses the severity of the BEPS phenomenon and assesses the anti-BEPS efforts of the OECD. Upon an assessment of these efforts, this thesis argues …