MULTILATERALISM, COORDINATED BI-UNILATERALISM OR CHAOS

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Presentation transcript:

MULTILATERALISM, COORDINATED BI-UNILATERALISM OR CHAOS María Teresa Soler MULTILATERALISM, COORDINATED BI-UNILATERALISM OR CHAOS Consistency and Hierarchy among the BEPS Actions

THE CONCEPT What BEPS Action Plan is really about María Teresa Soler Roch THE CONCEPT What BEPS Action Plan is really about Tackling base erosion and profit shifting Why: “agressive” tax planning / tax competition Which (tax base) Where (profit shifting) The Action Plan Two different approaches

THE TARGETS TAX AVOIDANCE TAX COMPETITION Treaty shopping. PPT necesary? Rule shopping? Artificial avoidance of PE. A better approach? TAX COMPETITION BEPS and tax incentives Preferential tax regimes (focused on PB)

THE TARGETS DOUBLE NON TAXATION FAIR SHARE (MNEs) (Legal) A new goal. Specific provisions? (Economic) Hybrids and other limitations Collateral dammages? FAIR SHARE (MNEs) Effectiveness of the Action Plan as a whole Relevant issues out of the scope of the BEPS project

THE LANDMARKS ECONOMIC SUBSTANCE and VALUE CREATION TRANSPARENCY TP issues more relevant Actions 3 and 5. Mismatches? TRANSPARENCY CbC reports more relevant Strategy disclosure. Future risks?

IMPLEMENTATION EFFECTIVENESS Overall approach María Teresa Soler IMPLEMENTATION EFFECTIVENESS Overall approach Different scenarios Different legal instruments Dispute resolution. Still too far from a TSDS system Digital economy. What to do?

IMPLEMENTATION DIFFERENT LEVELS Multilateralism . A work in progress Bilateral. Impact on the TT network Unilateral (DPT and the like) Supranational (EU) Risk of chaos? Last but not least: Court decisions