Volume 16, Issue 2 – Webster & Augustinos

TACKLING BASE EROSION AND PROFIT SHIFTING THROUGH ENHANCED INFORMATION EXCHANGE

By Katie Webster and Nicholas Augustinos

This article analyses the problem of base erosion and profit shifting (BEPS) and establishes how it can be targeted through information exchange systems. Particularly this article looks at the operation of information exchange provisions in existing bilateral Double Taxation Agreements (DTAs) and Tax Information Exchange Agreements (TIEAs) and examines their deficiencies. The last part of the article looks at tackling BEPS through the establishment of a new multilateral treaty focused on automatic information exchange and discusses what such an instrument would require.

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