The Resource A historical analysis of the BEPS Action Plan : old acquaintances, new friends and the need for a new approach

A historical analysis of the BEPS Action Plan : old acquaintances, new friends and the need for a new approach

Label
A historical analysis of the BEPS Action Plan : old acquaintances, new friends and the need for a new approach
Title
A historical analysis of the BEPS Action Plan : old acquaintances, new friends and the need for a new approach
Creator
Subject
Language
eng
Summary
This article analyses the issues raised by the base erosion and profit shifting (BEPS) Action Plan from a historical perspective. The author states that the innovation of the BEPS Project is the change in the public state of mind and attitude towards tax planning, as well as a totally new way of developing international tax rules through consensus with the participation of a broad number of countries. According to the author, future steps should take advantage of this actual innovation, get rid of previous analysis and, taking into account the current economic situation, study (1) the structure of the tax system and tax burden; (2) the jurisdiction to tax rules and the source and residence principles; and (3) the relationship between private law and tax law, i.e. legal personality and recognition of foreign persons and contracts. Without such in-depth analysis, any changes would be changes that only deepen already existent failing principles forming the base of the current system
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 46 (2018), no. 4 ; p. 278-295
Language note
English
Label
A historical analysis of the BEPS Action Plan : old acquaintances, new friends and the need for a new approach
Instantiates
Publication
Label
A historical analysis of the BEPS Action Plan : old acquaintances, new friends and the need for a new approach
Publication

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