BEPS and Allocation of Taxing Rights.
Author | Spencer, David |
Position | PERSPECTIVE |
The allocation of taxing rights between jurisdictions is a major international tax issue. The current analysis of this issue has largely been set in motion by the OECD/G20 base erosion and profit shifting (BEPS) project and by programs that other international organizations have initiated.
It's important to consider whether jurisdictions interested in reallocating taxing rights will be motivated to develop comprehensive and detailed proposals and to press for those proposals to be implemented. There are also possible common--or conflicting--interests with regard to reallocating taxing rights.
The OECD BEPS project affects the allocation and possible reallocation of taxing rights, through BEPS and otherwise. Several BEPS Actions directly affect the allocation of taxing rights, including the tax challenges posed by the digital economy; neutralizing the effects of hybrid mismatch arrangements; limiting base erosion through interest deductions and other financial payments; and countering harmful tax practices more effectively, taking into account transparency and substance. Allocating taxing rights does not always require international agreement, and in the context of income tax treaties, several possible scenarios exist whereby allocating taxing rights could pose challenges.
International tax issues, such as the allocation (reallocation) of taxing rights, have to be analyzed before a decision is made. The major changes in both substantive international tax rules and decision-making processes will affect how any allocation (reallocation) of taxing rights will be implemented. The OECD has taken steps...
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