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Tax Sovereignty in the BEPS Era by ROCHA

Tax Sovereignty in the BEPS Era

Edited by Sergio André Rocha, Allison Christians


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Series on International Taxation Volume 60

Tax Sovereignty in the BEPS Era focuses on how national tax sovereignty has been impacted by recent developments in international taxation, notably following the OECD/G-20 Base Erosion and Profit Shifting (BEPS) Project. The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with or even impedes that of another. In this collection of chapters, internationally respected practitioners and academics reveal how the OECD’s BEPS initiative, although a major step in the right direction, is insufficient in resolving the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post-BEPS world.

What’s in this book:

Following a country-by-country reporting structure, the contributors provide an in-depth analysis of such relevant issues as the following:

  • why multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy;
  • how digital commerce has upended traditional notions of source and residence;
  • why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system;
  • how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and
  • transfer pricing reform.

How this will help you:

This book helps readers navigate in these uncertain BEPS times, as well as provides insightful assessments on how countries’ tax policies might change in the near future. Through these chapters the authors provide authoritative commentaries on the necessary preconditions for exercising the power to tax in today’s world and the impacts of the emergence of the digital economy. Their perspectives and recommendations prove to be highly essential to all policymakers, legislators, practitioners, and academics in the international taxation arena regarding information that is essential for interpretation and decision-making in the current international tax environment.

Last Updated 06/20/2017
Update Frequency As Needed
Product Line Kluwer Law International
ISBN 9789041167071
SKU 10059520-0001
Table of Contents




Part I The Essential Paradox of Tax Sovereignty

Chapter 1 BEPS and the Power to Tax

Allison Christians            

Chapter 2 Tax Sovereignty and Digital Economy in Post-BEPS Times

Ramon Tomazela Santos & Sergio André Rocha

CHAPTER 3 Justification and Implementation of the International Allocation of Taxing Rights: Can We Take One Thing at a Time?

Luís Eduardo Schoueri & Ricardo André Galendi Júnior

Chapter 4 An Essay on BEPS, Sovereignty, and Taxation

Part II    Challenge to the Foundational Principles of Source and Residence

Chapter 5 Evaluating BEPS

Reuven S. Avi-Yonah & Haiyan Xu

Chapter 6 Jurisdictional Excesses in BEPS’ Times: National Appropriation of an Enhanced Global Tax Basis

Guillermo O. Teijeiro

Chapter 7 Taxing the Consumption of Digital Goods

Aleksandra Bal

Part III  Acceptance and Implementation of Consensus by Differently-Situated States

Chapter 8 The Birth of a New International Tax Framework and the Role of Developing Countries

Natalia Quiñones

Chapter 9 The Other Side of BEPS: “Imperial Taxation” and “International Tax Imperialism”

Sergio André Rocha

Chapter 10 Country-by-Country Over-Reporting? National Sovereignty, International Tax Transparency, and the Inclusive Framework on BEPS

Romero J.S. Tavares

Chapter 11 How Are We Doing with BEPS Recommendations in the EU?          

Tomas Balco & Xeniya Yeroshenko        

Chapter 12 U.S. Tax Sovereignty and the BEPS Project

Tracy A. Kaye