• April 9th, 2016


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Globalization has impacted positively on our economies. Countries have integrated, exchanged views and are able to carry out businesses with the advent of e-commerce. The world no longer seems to be so big but a small village. Multinationals shifts their profits to tax havens making some part or all of their profits not being taxed at all. The introduction of the BEPS action plans by OECD has caused a lot of economies to consider a change to their legislative process, adjust legislation and thereby reduce multinational profit shifting. The action plans are able to expose MNE’s aggressive tax planning strategies and close loopholes used by them.

There are arguments that these action plans would not benefit developing countries. It is argued that the action plans does not consider the capital base of developing countries, cross border tax planning differs from developed and developing countries, developing countries lack the legislative measures to address BEPS (i.e. outdated tax laws), there is difficulty in accessing relevant information, they also lack the capacity to implement highly complex international rules to challenge well advised and experienced MNE’s, and lastly the lack political impetus and support for effective measures to counter BEPS.

While this thesis addresses these challenges and finds possible solutions it will be recommended that the OECD adopts some new action points for developing countries because the currents plans are not feasible to the developing countries. Lots of Developing countries do not have functioning legislations to address Anti-avoidance and base erosion and profit shifting.

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