Addressing Base Erosion and Profit Shifting Activities in an Increasingly Digital Economy: Role of Computer Forensics and Emerging Areas of Research

Addressing Base Erosion and Profit Shifting Activities in an Increasingly Digital Economy: Role of Computer Forensics and Emerging Areas of Research

Copyright: © 2018 |Pages: 19
DOI: 10.4018/978-1-5225-4131-8.ch017

Abstract

In consolidating its contribution to extant literature on the current topic, this chapter is dedicated to highlighting emerging areas of research – in respect of the topic, as well as addressing identified issues.
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Literature Review

The Organization for Economic Cooperation and Development released its final recommendations in its 2015 Final Reports (OECD, 2015) – along with highlights of its fifteen key action points:

  • Action 1: Addressing the Tax Challenges of the Digital Economy

  • Action 2: Neutralizing the Effects of Hybrid Mismatch Arrangements

  • Action 3: Designing Effective Controlled Foreign Company Rules

  • Action 4: Limiting Base Erosion Involving Interest Deductions and Other Financial Payments

  • Action 5: Countering Harmful Tax Practices More Effectively, Taking into Account Transparency and Substance

  • Action 6: Preventing the Granting of Treaty Benefits in Inappropriate Circumstances

  • Action 7: Preventing the Artificial Avoidance of Permanent Establishment Status

  • Actions 8-10: Aligning Transfer Pricing Outcomes with Value Creation

  • Action 11: Measuring and Monitoring BEPS

  • Action 12: Mandatory Disclosure Rules

  • Action 13: Transfer Pricing Documentation and Country-by-Country Reporting

  • Action 14: Making Dispute Resolution Mechanisms More Effective

  • Action 15: Developing a Multilateral Instrument to Modify Bilateral Tax Treaties

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