Abstract:

The paper explores a topic of global importance, for which the Group of Twenty governments, whose economies account for around 90% of the gross world product, have recently called on the Organization for Economic Cooperation and Development to develop an action plan to address the Base Erosion and Profit Shifting issues in the most efficient and comprehensive manner. The rapidly changing business models and technological developments have created weaknesses in the international tax framework that created opportunities for the Base Erosion and Profit Shifting, therefore the realignment of taxation with relevant economic substance became necessary.