What is a permanent establishment? Income tax treaties of developed countries typically include standard language defining the term permanent establishment that is based on the OECD…
OCED-Corporate-Tax-Avoidance Download Factsheet
Base Erosion and Profit Shifting (BEPS) refers to tax planning strategies that exploit these gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid. BEPS is of major significance for developing countries due to their heavy reliance on corporate income tax, particularly from multinational enterprises (MNEs).
Research undertaken since 2013 confirms the potential magnitude of the BEPS problem. Estimates conservatively indicate annual losses of anywhere from 4 – 10% of global corporate income tax (CIT) revenues, i.e. USD 100 to 240 billion annually.