Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adop

Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adop

Limiting base erosion from different viewpoints Hybrid mismatch arrangements, CFC rules, transfer pricing rules: “Limiting Base Erosion”, the general topic

This book provides a comprehensive analysis of current techniques for profit shifting and tax base erosion in the area of corporate taxation and measurement. Fi

The 2015 Report on BEPS Action 4 established a common approach which directly links an entity’s net interest deductions to its level of economic activity, bas