Читать книгу Global Tax Governance. Taxation on Digital Economy, Transfer Pricing and Litigation in Tax Matters (MAPs + ADR) Policies for Global Sustainability. Ongoing U.N. 2030 (SDG) and Addis Ababa Agendas онлайн
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In the field of tax justice in respect of taxpayers’ position, the different initiatives developed since the OECD BEPS project was launched in 2013 and specially more recent proposals, show a tendency to avoid situations of double non (or low) taxation, as well as a revision of traditional principles such as benefit and ability to pay (value creation, fair share) and the nexus with the source country (market jurisdiction); however, new risks of double taxation may arise, thus undermining the fairness of the system from a taxpayer’s perspective.
In the field of tax justice in respect of the States, the current work show a tendency to set up a new level playing field for inter-nation equity, including the proposal of new taxing rights in favor of the source/market jurisdictions countries. This new framework deals with “how to share the pie” and therefore needs cooperation and consensus; a most difficult goal in this case and thus an uncertain outcome for the time being, taking into account the divergent positions between separate entities and arms’ length defenders on one side, and the proposals for consolidation and apportionment on the other.