UN transfer pricing manual: what Brazil, India and China do differently

‘Country Practices’. The title of Chapter 10 of the new United Nations Practical Manual on Transfer Pricing [pdf] doesn’t exactly set the pulse racing. But as I noted in my blog on the manual as a whole, this document is politically very significant. It’s probably the only detailed description of Brazil, China, India and South… Continue reading UN transfer pricing manual: what Brazil, India and China do differently

Do the BRICS present a challenge to the governance of international tax?

For campaigners, journalists and academics, the more interesting answer to the title question of this post would clearly be “yes”. It’s fascinating to think that we might be living through a paradigm shift in the politics of international tax, with the OECD struggling to maintain its relevance in the face of a more and more… Continue reading Do the BRICS present a challenge to the governance of international tax?

What did we learn from yesterday’s BEPS ‘tweetchat’?

140 character exchanges are unlikely to be the most revealing and nuanced on a topic as complex as the OECD’s ‘base erosion and profit shifting‘ project. But it was interesting that the OECD decided to reach out in this way, and also that questions did not just come from the usual suspects – the Institute… Continue reading What did we learn from yesterday’s BEPS ‘tweetchat’?

On the BRICS’ choice of diplomatic language at the OECD

I’ve just been reading through the 2010 update to the OECD model tax treaty [pdf] and in particular the different positions set out by non-OECD countries. This is where countries can put on record their objections to the model treaty, so that potential treaty partners know what they’re getting themselves into. I think the difference… Continue reading On the BRICS’ choice of diplomatic language at the OECD

ActionAid on the global fight against tax havens

Well, happy 40th birthday ActionAid. Beginning as a small London-based child sponsorship initiative, my former employer had grown into a truly global federation of development organisations. Form follows function, and the brilliant decision to relegate ActionAid’s UK office from headquarters to one member of a federation with the same number of votes as, say, ActionAid Malawi is… Continue reading ActionAid on the global fight against tax havens

Is eBay avoiding tax? (In which I endeavour to improve on a post by Mr Tim Worstall)

On Monday I discussed how I think most of the real debate about corporate tax scandals is about people’s normative interpretations of the tax system, not the technicalities of the particular structures. Then I read this: Another day, another report of an internet company avoiding taxes in the UK. This time it’s eBay, to follow… Continue reading Is eBay avoiding tax? (In which I endeavour to improve on a post by Mr Tim Worstall)