Special Issue on Base Erosion and Profit Shifting - Bulletin for International Taxation


Wolfgang Schön et. al.

In January 2014, the Max Planck Institute for Tax Law and Public Finance together with the International Network for Tax Research (INTR) hosted in Munich a two-day interdisciplinary conference on the OECD's Action Plan on Base Erosion and Profit Shifting. The fundamental premise of the BEPS project is that a coordination of national responses to BEPS can both eliminate double non-taxation and protect against material unrelieved double taxation. The articles on BEPS in this special issue of the Bulletin for International Taxation further a dialogue among tax policymakers, taxpayers, advisors and academics that is critical to achieve this objective. They are based on papers first presented at the Munich conference.



Base Erosion and Profit Shifting: A Roadmap for Reform
Hugh J. Ault, Wolfgang Schön and Stephen E. Shay

Articles on Base Erosion and Profit Shifting

International Taxation of Risk
Wolfgang Schön

Transparency in Financial Reporting: Is Country-by-Country Reporting Suitable to Combat International Profit Shifting?
Maria Theresia Evers, Ina Meier and Christoph Spengel

Transparency and Financial Accounting
Jennifer Blouin

"Tax Arbitrage" with Hybrid Entities: Challenges and Responses
Jürgen Lüdicke

Base Erosion and Profit Shifting: A Roadmap for Reform - Tax Arbitrage with Hybrid Instruments
Stephen Edge

The Role of Controlled Foreign Company Legislation in the OECD Base Erosion and Profit Shifting Project
Mitchell A. Kane

Controlled Foreign Company Legislation, Corporate Residence and Anti-Hybrid Arrangement Rules
Guglielmo Maisto

Base Erosion and Profit Shifting and Interest Expenditure
Johanna Hey

Jurisdiction to Tax in the Digital Economy: Permanent and Other Establishments
Walter Hellerstein

Intangibles and Location Benefits (Customer Base)
J. Scott Wilkie

Inter-Nation Competitiveness: A Discussion Paper on Base Erosion and Profit Shifting
Rosanne Altshuler


China and Australia's Responses to Environmental Challenge: A Comparative Analysis - Environmental Tax Reforms
Benny Hu and Richard S. Simmons

Cross-Border Loss Utilization
Jürgen Lüdicke, Jürg B. Altorfer, Gauthier Blanluet, Daniela Hohenwarter-Mayr, Koichi Inoue, Steve Suarez and Carolin Lange-Hückstädt

Japanese Taxation of Trusts
Yuya Suzuki

Effective EU Tax Collection: A Utopia
Paul van der Smitte

Published:   Bulletin for International Taxation, 2014, Volume 68, No. 6/7.