Tax Sovereignty in the BEPS Era
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.
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Part I The Essential Paradox of Tax Sovereignty
Chapter 1 BEPS and the Power to Tax
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
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
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