Excerpt
June 2023, Opinion: "Recent efforts to make large, multinational corporations pay their “fair share” of taxes have been predicated on the idea that there is a significant amount of income of these companies that remains untaxed or undertaxed. This happens due to “profit-shifting” or the relocation of profits from high tax to low tax jurisdictions within firms that operate across multiple countries. The recent two-part OECD/G20 initiative – first, to reallocate taxing rights to countries that are markets for companies, and second, to impose a global minimum tax at a jurisdictional level – suggests that efforts to curb these avoidance activities will subject an additional US$125-150 billion in profits to tax. This is the impetus behind the OECD Base Erosion and Profit Shifting Project (BEPS) that began in 2013 and that has taken recent shape in the two-pillar approach. However, despite nearly a decade of work by the OECD on this issue, profit shifting remains an ill-defined term. We know surprisingly little about the true extent of profit shifting across countries, and how profit shifting impacts the real economy. Before countries fundamentally reorganise their tax systems to address the challenge of profit shifting, perhaps we need to pause and take stock of what we know."